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[2009] VCAT 888
Victorian Civil and Administrative Tribunal
2009-05-13
Mr P
Original judgment source is linked above.
Charter of Human Rights and Responsibilities Act 2006 - s 33 application for referral to the Supreme Court - application granted.
Bevnol Constructions & Developments Pty Ltd (ACN 079 170 577), Bruce Jamieson and Louis Allain
De Simone v Bevnol Constructions & Developments Pty Ltd & Ors (Domestic Building) [2009] VCAT 888
The following question is referred to the Supreme Court for determination pursuant to s 33 of the Charter of Human Rights and Responsibilities Act 2006 -
"Given that the Tribunal has an implied statutory power to stay a civil proceeding, whether the McMahon v Gould guidelines applicable to that power should be revised in light of the Charter of Human Rights and Responsibilities Act 2006, and in particular ss 24 and 25 of that act and, if so, how."
For Bevnol Constructions & Developments Pty Ltd and the Second and Third Respondents:
"1. Mr De Simone has been the subject of a police investigation involving allegations of obtaining a financial advantage by deception. The investigation was instigated following a complaint made by a director of Bevnol in about March 2007.
'In the VCAT proceedings the applicant submitted that McMahon required modification in light of ss 24 and 25 of the Charter. He claimed that a stay was required because the VCAT proceedings would prejudice his right under s 24 to have the charge determined by a competent, independent and impartial court after a fair and public hearing, and his right to a fair criminal trial under s 25, including the right to silence recognised by s 25(2)(j)'[5]
'We doubt whether s 24 of the Charter requires modification of the McMahon principles, which emphasise the protection of the accused's right to silence in criminal proceedings and attempt to balance it against the rights of the parties in civil proceedings. Nevertheless we consider that the applicant has a real argument that the McMahon principles should be modified in light of ss 24 and 25 of the Charter.' [my emphasis][8]
'the matter has been somewhat overtaken by events. The applicant has now been charged as anticipated. It is open to him to make a fresh stay application in these altered circumstances, bearing in mind that the judge reached his conclusion in part on the basis that s 25 of the Charter did not apply to persons who were only under investigation. His Honour did not exercise his discretion in the circumstances which now prevail and there would be no utility in the Court considering the challenge the applicant presently seeks to ventilate on appeal.'[9]
"(1) If, in a proceeding before a court or tribunal, a question of law arises that relates to the application of this Charter or a question arises with respect to the interpretation of a statutory provision in accordance with this Charter, that question may be referred to the Supreme Court if -
(a) a party has made an application for referral; and
(b) the court or tribunal considers that the question is appropriate for determination by the Supreme Court."
"1. Is there an operative difference in application of the requirement of VCAT to afford a "fair hearing" in proceeding D916/2006 under section 97 of the VCAT Act with the obligation of VCAT to ensure a "fair hearing" under section 24 of the Charter of both the criminal and civil proceedings?
"Given that the Tribunal has an implied statutory power to stay a civil proceeding, whether the McMahon v Gould guidelines applicable to that power should be revised in light of the Charter of Human Rights and Responsibilities Act 2006, and in particular ss 24 and 25 of that act and, if so, how."
[1] Paul Marc Custodians Pty Ltd (ACN 110 485 982) formerly known as Paul Marc Management Pty Ltd was the third respondent; Martin Jurblum, a director of Paul Marc Custodians Pty Ltd, was the fourth respondent.
[2] Seachange Management Pty Ltd v Bevnol Constructions &Developments Pty Ltd & Ors (Domestic Building) [2008] VCAT 2629
[4] Dowie v Northey and Anor [2000] VCAT 823 (30 April 2000); LU Simon Buildings v Lubica Systems Aust Pty Ltd per Judge Duggan [2001] VCAT 2217 (20 November 2001) and Browne v Greenleaf Nominess Pty Ltd per Deputy President Aird [2006] VCAT 1646 (11 August 2006).
[5] Giuseppe De Simone v Bevnol Constructions and Developments Pty Ltd, VSCA No 3933 of 2008 at para [34]
[6] Ibid para [44]. Re AWB Limited [2008] VSC 473; (2008) 252 ALR 566
[7] [2008] VSC 473; (2008) 252 ALR 566 at 591
[11] (General) [2009] VCAT 646
De Simone
Bevnol Constructions & Developments Pty Ltd & Ors
(1995) 184 CLR 1
(2008) 252 ALR 566