© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2021] NSWCA 111
Court of Appeal (NSW)
2021-03-24
Basten JA, Macfarlan JA, Walton J
Original judgment source is linked above.
Solicitors: The People's Solicitors (Appellants) Dentons Australia Limited (First Respondent) Crown Solicitor's Office (Second Respondent) File Number(s): 2019/373368; 2020/132518 Decision under appeal Court or tribunal: Supreme Court of New South Wales Jurisdiction: Common Law Citation: [2019] NSWSC 1477; [2020] NSWSC 283 Date of Decision: 29 October 2019; 23 March 2020 Before: Walton J File Number(s): 2015/27843; 2016/122304
[Note: The Uniform Civil Procedure Rules 2005 provide (Rule 36.11) that unless the Court otherwise orders, a judgment or order is taken to be entered when it is recorded in the Court's computerised court record system. Setting aside and variation of judgments or orders is dealt with by Rules 36.15, 36.16, 36.17 and 36.18. Parties should in particular note the time limit of fourteen days in Rule 36.16.]
HEADNOTE [This headnote is not to be read as part of the judgment] In 2002 Ms Charlton, the first appellant, entered into a contract for the purchase of a farming property situated at Five Ways in western New South Wales. The contract described her as "trustee for Phoenix Trust". The Trust was established in 1996 and Ms Charlton was appointed as a trustee in 2001. In 2007 Ms Charlton granted a mortgage over the Five Ways property to NAB, the first respondent, as security for financial facilities provided (or to be provided) to her by NAB. She was named as mortgagor without any reference to the Trust. In 2011 Ms Charlton defaulted in compliance with the terms of the financial facilities, resulting in NAB making demands for payment upon her. Ms Charlton alleged that she retired as a trustee in 2011. In 2013, after receiving a complaint made by Ms Charlton, the Financial Ombudsman Service concluded that Ms Charlton was liable to pay the amounts secured by the mortgage. However, the Ombudsman further found that, as Ms Charlton was a "farmer" at the relevant time, NAB was required to send her a notice offering mediation under s 8 of the Farm Debt Mediation Act 1994 (NSW). NAB subsequently issued a s 8 notice and a mediation between Ms Charlton and NAB was held in 2014. The Rural Assistance Authority held that a satisfactory mediation had taken place and issued a s 11 certificate certifying that the Act did not apply to the mortgage. In 2015 NAB commenced proceedings against Ms Charlton in the Common Law Division of the Supreme Court seeking possession of the Five Ways property and judgment against her for the amount owing under the financial facilities. Ms Charlton brought a cross-claim and commenced separate proceedings seeking judicial review of the s 11 certificate. The primary judge rejected Ms Charlton's cross-claim, dismissed her summons seeking judicial review and gave judgment to NAB for possession of the property and judgment against Ms Charlton in the sum of $1,838,388. The primary issues on appeal were: (1) Whether Ms Charlton's alleged retirement from the Trust meant that she was not liable for the debts owed to NAB; (2) Whether alleged non-adherence to the Farm Debt Mediation Act 1994 (NSW) precluded NAB from prosecuting its claims. The Court dismissed the appeal: (Per Macfarlan JA at [21], Basten JA and Emmett AJA agreeing at [3] and [93] and adding further observations). In relation to Issue 1 (Ms Charlton's liability for debts owed to NAB): The trust deed did not provide express authority for unilateral retirement and there was no lacuna to be filled by implying such a power: [38], [43]. Therefore, Ms Charlton's purported retirement was ineffective: [38], [88]. Bunten v Muir (1894) 21 R 370, distinguished. Even if Ms Charlton validly retired as a trustee, she still remained liable for the debts claimed by NAB as they were incurred prior to her purported retirement: [47], [84], [85]. That the debts were allegedly not yet payable at the time of the purported retirement does not mean that they were not liabilities: [46], [84]. In relation to Issue 2 (NAB's compliance with the Farm Debt Mediation Act): Ms Charlton was the only relevant farmer for the purposes of the Act because she was the person who granted the mortgage. Therefore, Ms Charlton was the only farmer who was required to be present at the mediation. The mediation held in 2014 was thus valid: [48]-[49], [87]. Further, NAB was entitled to enforce the debt owing under the financial facilities as Ms Charlton's obligations arose from the facility agreements rather than the mortgage: [63], [65], [91]. Such enforcement action was therefore not void under the Act. Waller v Hargraves Secured Investments Ltd (2012) 245 CLR 311; [2012] HCA 4, applied. (Further observations per Basten JA regarding the judicial review proceeding): The primary judge refused to grant leave to extend time for Ms Charlton to bring a summons seeking judicial review of the s 11 certificate. On appeal, there was no challenge to that decision and, for that reason, grounds which sought only to challenge the validity of the certificate could not be addressed: [6], [13].
Judgment
FARM DEBT MEDIATION ACT 1994 (NSW)
THE JUDGMENTS AT FIRST INSTANCE
Issue 1: whether a "satisfactory mediation" was held for the purposes of the FDMA
Issue 2: whether NAB's actions in 2011 constituted "enforcement action", such that the proceedings initiated by NAB were void by s 6 of the Act
Issue 3: alleged misrepresentations concerning refinance and other matters
Issue 4: right of indemnity issue
Issue 5: service of the s 57 default notice
Issues 6 to 9: other issues
DETERMINATION OF THE APPEAL
Ground 1: the primary judge erred in finding that Ms Charlton did not retire as trustee in 2011
Relevance of resignation of trustee
Ground 2: whether Mr O'Brien was a or the farmer for the purposes of the FDMA
Ground 3: whether NAB should have served a s 8 notice on Mr O'Brien
Ground 4: the s 8 notice was defective
Grounds 5 to 8 and 11: NAB took enforcement action within the meaning of s 10 of the FDMA prior to the mediation
Ground 9: the mediation was not "satisfactory" within the meaning of s 11 of the FDMA
Ground 14: the proceedings for judicial review of the s 11 certificate should not have been dismissed
Ground 10: NAB did not establish its right to possession of the mortgaged property
Ground 13: the primary judge erred in determining the identity of the trustee or trustees of the Phoenix Trust
Ground 15: the primary judge erred in assessing the quantum of NAB's money claim
Ground 16: the primary judge erred in entering judgment against Ms Charlton in debt as well as for possession of the mortgaged property
ORDERS
Endnotes
Charlton
National Australia Bank Limited
(2014) 89 NSWLR 209
(2008) 238 CLR 570
(1982) 150 CLR 139
(2019) 93 ALJR 807
(1997) 42 NSWLR 252
(1992) 26 NSWLR 562
(1996) 185 CLR 149
(1976) 50 ALJR 471
(1991) 26 NSWLR 361
(2012) 245 CLR 311