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[1999] VSC 131
Supreme Court of Victoria
1999-04-28
Gillard J
Original judgment source is linked above.
Australian Hospital Care Pty Ltd & Anor v. Duggan & Ors (No. 2)
Discovery of documents - Objection to production - Legal professional privilege - Salaried employee lawyer - Privilege available - Independence of lawyer - Whether necessary - Onus - Proof - Acting independently
For the First to Twenty First Defendants (inclusive)
"The documents enumerated in Part 2 of Schedule 1 are privileged and I object to produce them. The documents are privileged on the grounds that they have been brought into existence for the sole purpose of providing legal advice to the Plaintiffs and/or in contemplation of the Plaintiffs instituting this Proceeding or enabling the Plaintiffs to prosecute this Proceeding."
Internal memorandum of Australian Hospital Care Limited from Rod McNeil to Group Leadership Team.
Internal memorandum of Australian Hospital Care Limited from Rod McNeil to Peter Selar and David Carruthers.
Internal memorandum of Australian Hospital Care Limited from Rod McNeil to Mark Bryce and Richard Royle.
Internal memorandum of Australian Hospital Care Limited from Rod McNeil to Mark Bryce.
"The law relating to discovery was developed by the Chancery Courts in the first half of the 19th century. At that time nearly all legal advisers were in independent practice on their own account. Nowadays it is very different. Many barristers and solicitors are employed as legal advisers, whole time, by a single employer. Sometimes the employer is a great commercial concern. At other times it is a government department or a local authority. It may even be the government itself, like the Treasury Solicitor and his staff. In every case these legal advisers do legal work for their employer and for no one else. They are paid, not by fees for each piece of work, but by fixed annual salary. They are no doubt servants or agents of the employer ... They are regarded by the law as in every respect in the same position as those who practise on their own account. The only difference is that they act for one client only, and not for several clients. They must uphold the same standards of honour and of etiquette. They are subject to the same duties to their client and to the court. They must respect the same confidences. They and their clients have the same privileges."
"Being a servant or agent too, he may be under pressure from his client. So he must be careful to resist it. He must be as independent in the doing of right as any other legal adviser. It is true, as the Law Reform Committee said in their report in 1967 on Privilege in Civil Procedure that the 'system is susceptible to abuse' but I have never known it abused. ... There is a safe guard against abuse ... If there is any doubt as to the propriety or the validity of a claim for privilege, the Master or Judge should without hesitation inspect the documents himself so to see if the claim is well founded or not."
"I do not doubt the correctness of the decision of the Court of Appeal in Alfred Crompton Amusement Machines Ltd v. Customs and Excise Commissioners (No. 2) that the privilege extends to legal advice given by such employees provided that in giving the advice they are acting in their capacity as legal advisers."
"This is, however, no reason for denying privilege to communications passing between them and their client provided that they are consulted in a professional capacity in relation to a professional matter and the communications are made in confidence and arise from the relationship of lawyer and client."
"In our opinion, given the safeguards to which reference is made in the various citations, there is no reason to place legal officers in government employment outside the bounds of legal professional privilege. The proper functioning of the legal system is facilitated by freedom of consultation between the client and the legal adviser."
" ... There is authority in this court and elsewhere for the proposition that legal professional privilege may attach to communications passing between a salaried legal adviser and his employer, provided that the legal adviser is consulted in a professional capacity in relation to a professional matter and the communications are made in confidence and arise from the relationship of lawyer and client. For this reason the legal adviser must be qualified to practise law and it seems, subject to the duty to observe professional standards and the liability to professional discipline."
(i) arises as a result of the employer consulting the employee in a professional capacity;
(ii) is in relation to a professional matter;
(iii) is made in confidence;
(iv) arises from the relationship lawyer and client,
see Dawson J in Kearney's case, supra at pp.530-1 quoted by Mason and Wilson JJ in Waterford's case, supra at p.61.
and
(v) satisfies one of the tests laid down in Grant v. Downes.
"So he must be careful to resist it. He must be as independent in the doing of right as any other legal adviser."
" ... It should be stated that the requirement as to the position and status as an independent lawyer, which must be fulfilled by the legal adviser from whom the written communications which may be protected emanate, is based on a conception of the lawyer's role as collaborating in the administration of justice by the courts and as being required to provide, in full independence, and in the overriding interest of that cause, such legal assistance as the client needs. The counterpart of that protection lies in the rules of professional ethics and discipline which are laid down and enforced in the general interest by institutions endowed with the requisite powers for that purpose. Such a conception reflects the legal traditions common to the member States ... "
"Provided the communications in question are exchanged between an independent lawyer, that is to say one who is not bound to his client by a relationship of employment, and his client."
"The advice will not be privileged if the legal adviser gives it in some other capacity (e.g. as an officer of a non-legal department) and will be privileged only if the lawyer who gives it has been admitted to practice and (I incline to think) remains subject to the duty to observe professional standards and the liability to professional discipline. However, these matters were not explored in argument before us."
"To our minds it is clearly in the public interest that those in government who bear the responsibility of making decisions should have a free and ready confidential access to their legal advisers. Whether in any particular case relationship is such as to give rise to the privilege will be a question of fact. It must be a professional relationship which secures to the advice an independent character notwithstanding the employment."
"If the purpose of the privilege is to be fulfilled, the legal adviser must be competent and independent. ... Independent, in order that the personal loyalties, duties or interests of the adviser should not influence the legal advice which he gives or the fairness of his conduct of litigation on behalf of his client. If a legal adviser is incompetent to advise or to conduct litigation or if he is unable to be professionally detached in giving advice or in conducting litigation, there is an unacceptable risk that the purpose for which privilege is granted will be subverted."
"I am therefore unable to accept the notion that salaried lawyers are generally to be assimilated to the position of the independent legal profession for the purpose of determining the availability of legal professional privilege. Although this view may seem to give insufficient acknowledgement to the personal integrity, as well as the competence, of many salaried lawyers, we are concerned with the general legal rule which is framed not with regard to the characteristics of individuals but with regard to the influences that naturally attend the relationship of employer and employee."
"Another, and more significant, criticism is that Lord Denning appears to me to unduly discount the importance, from the point of view of both the need for and the prevention of abuse of the privilege, of the matters mentioned in the above extract from the opinion of the European Court in the A.M. and S. case, particularly the importance of the 'full independence' of the independent lawyer."
"For this reason the legal adviser must be qualified to practise law and it seems, subject to the duty to observe professional standards and the liability to professional discipline."
"If there is any doubt as to the propriety or validity of a claim for privilege the Master or the Judge should without hesitation inspect the documents himself so as to see if the claim is well founded, or not.
He has ample power under R.S.C.Ord. 24r12. The affidavit should not be treated as conclusive nor anything like it. A party cannot use the affidavit as a taboo or spell to prevent anyone looking at the documents. When the Master or Judge sees the documents, he will see if the privilege is rightly claimed - or not - and make an order accordingly."
"It is for the party claiming privilege to show that the documents for which the claim is made are privileged. He may succeed in achieving this objective by pointing to the nature of the documents or by evidence describing the circumstances under which they were brought into existence. But it should not be thought that the privilege is necessarily or conclusively established by resort to any verbal formula or ritual. The court has power to examine the documents for itself, a power which has perhaps been exercised too sparingly in the past, springing possibly from a misplaced reluctance to go behind the formal claim of privilege."
"But there is nothing in the Rule, or in the authorities, to constrain the court to hold that, in every case where a claim to privilege is made and disputed, the party seeking production is entitled to come to the court and (as it were) demand as a right that the court should go behind the oath of the opposite party and itself inspect the documents. The question whether the court should inspect the documents is one which is a matter for the discretion of the court, and primarily for the judge at first instance. Each case must depend on its own circumstances; but if, looking at the affidavit, the court finds that the claimed privilege is formally correct, and that the documents in respect of which it is made are sufficiently identified and are such that, prima facie, the claim to privilege would appear to be properly made in respect of them, then in my judgment, the court should, generally speaking accept the evidence as sufficiently justifying the claim without going further and inspecting the documents."
(i) that the evidence in confidential Exhibit PJH5 to the affidavit of Peter John Holloway demonstrated that Mr McNeil was directly involved in acquisition of businesses by the plaintiffs including the one the subject of the proceeding;
(ii) the difficulty in obtaining information from the plaintiffs' solicitor Mr Fagenblat, the reluctance to provide information and in particular the failure to respond to the questions of independence and of Mr McNeil's right to practise law in this State;
(iii) that Mr McNeil although admitted to practice in Victoria in July 1998 did not hold any practising certificate nor was he registered with the Victorian Bar Council and accordingly was not permitted to practise law in this State.
"As general counsel at AHC (Australian Hospital Care Ltd) I provide legal advice, in the first instance, both to AHC and to its subsidiaries including the plaintiffs in this proceeding. Where it is determined appropriate, external lawyers may be consulted by AHC and/or its subsidiaries. On these occasions I generally continue working with the external lawyers to provide legal advice to AHC and its subsidiaries. In respect of the documents which have been discovered by the plaintiffs in this proceeding each of the documents numbered 132, 137, 178 and 194 in the plaintiffs' affidavit of documents and supplementary affidavit of documents was created by me in my capacity as general counsel of the AHC solely for the purpose of providing legal advice and in contemplation and for the purpose of progressing this litigation."
"I am presently admitted as a solicitor of the Supreme Court of New South Wales, a solicitor admitted to the High Court of England and Wales, solicitor admitted to the Supreme Court of Hong Kong and a solicitor admitted to the Supreme Court of Victoria. I was admitted in the Supreme Court of Victoria in 1998."
"In that regard (ie. Mr McNeil) it is apparent to us from the documents that we have seen that Mr McNeil occupied a non-legal function within your clients and there is a real issue as to whether the documents created by Mr McNeil or sent to him which are said to be amenable to a claim to legal professional privilege, are in fact privileged."
"There is nothing in Mr McNeil's affidavit which addresses this issue."
"(c) is an interstate practitioner (other than an interstate practitioner who is suspended or prohibited from engaging in legal practice in Victoria)."
(i) that the plaintiffs produce for inspection by a Judge of this court the documents numbered 132, 137, 147 and 178 in the affidavit of documents sworn by John Kenneth Nelson on 16 March 1999 and filed in this proceeding on behalf of the plaintiff;
(ii) that the plaintiffs pay the twenty third and twenty fourth defendants' costs of the twenty third and twenty fourth defendants' summons filed 14 April 1999.
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Australian Hospital Care Pty Ltd
Duggan
(1987) 163 CLR 54
(1987) 14 NSWLR 100
(1985) 158 CLR 500
(1990) 23 NSWLR 548