Dehsabzi v Afghan Community Support Association of NSW Inc

Association's Constitution

When the Association was incorporated in April 2008, the applicable legislation was the Associations Incorporation Act 1984 (NSW) ("AIA 1984"). The Association's constitution became (by default, no other constitution having been specified in the application for incorporation) the model rules in the form then prescribed in Schedule 1 to the Associations Incorporation Regulation 1999 (NSW). I will refer to these as the "2008 Model Rules".
Later the AIA 1984 was repealed and replaced by the Associations Incorporation Act 2009 (NSW) ("AIA 2009"). This did not affect the constitution of the Association, which remained governed by the 2008 Model Rules.
In July 2014, a new document was recorded by FTNSW on the Register of Incorporated Associations as the constitution of the Association. I will refer to this document as the "2014 Constitution". The document was recorded on the Register following its lodgement, purportedly on behalf of the Association, on about 9 July 2014.
The 2014 Constitution was lodged with FTNSW as an annexure to a form apparently signed by Mohammed Sharif Amin, who was described in it as the Public Officer of the Association. The form stated that a special resolution was passed at a general meeting of the members of the Association on 29 June 2014 which adopted the 2014 Constitution as the new constitution of the Association.
In their Statement of Claim, the plaintiffs allege that Mr Amin was not in fact the Public Officer of the Association when the form was lodged and that the 2014 Constitution was not in fact adopted by the Association at the June 2014 general meeting. The latter allegation was supported at the hearing before me by evidence from one of the plaintiffs, Abdul Quddus Ebrahimi. In his affidavit, Mr Ebrahimi stated that he was present at the meeting on 29 June 2014 and no resolution in the terms stated in the form lodged by Mr Amin was passed on that occasion.
The active defendants' defence admitted that Mr Amin was not the public officer of the Association and that the 2014 Constitution was not adopted by the Association. On the face of it, it was therefore common ground between the plaintiffs and the active defendants that the 2014 Constitution was invalid. But the active defendants' defence raised two points by way of qualification, or potential qualification.
The first point raised in the defence was based on AIA 2009 s 14(1). That section provides: Effect of registration of change of name, objects, constitution or official address (1) A change of name, objects, constitution or official address that is registered under this Division takes effect when it is registered. The defence pleaded that, as a result of this provision, even if the 2014 Constitution was improperly lodged with FTNSW, for as long as it remained on the Register, it was effective as the constitution of the Association.
The second point raised in the defence concerned Mr Amin's position. The defence pleaded that he may have been guilty of an offence under the Crimes Act 1900 (NSW), s 307B. That enactment makes it a crime to knowingly provide false information to a public authority. The defence pleaded that as a matter of procedural fairness, Mr Amin ought to be joined as a defendant. Implicitly the defence appeared to be saying that the Court should not determine the validity of the 2014 Constitution unless that had happened.
At the hearing on 9 July, counsel for the plaintiffs pressed me to make final orders declaring the 2014 Constitution invalid. Counsel for the active defendants did not resist my dealing with the issue but drew attention to the two qualifying points made in the defence.
It is convenient to deal first with the point concerning Mr Amin. The question in these proceedings is simply whether the 2014 Constitution was in fact adopted by the Association. As the defence itself acknowledged, Mr Amin would not have been guilty of an offence unless (at least) the statements made in the form were knowingly incorrect. It was not necessary to make, and I have not made, any finding to that effect. In these circumstances, there was no need to join Mr Amin.
The point raised in the defence concerning the effect of s 14(1), is contested. Counsel for the plaintiffs submitted that the section did not have the effect that a constitution recorded on the Register is in some way indefeasible, like title to land under Torrens legislation.
I did not find it necessary to decide this question at the hearing. Even if the defendants' contention is correct, it constituted no reason to maintain the 2014 Constitution on the Register. The consensus of the parties, as reflected in the pleadings, and as confirmed by the evidence, was that the statements in the form which accompanied the 2014 Constitution were false. It should never have been lodged and registered in the first place. For these reasons, at the end of the hearing on 9 July I made an order that the 2014 Constitution be removed forthwith from the Register.

Appointment of receiver

AIA 2009, s 28, relevantly provides: Committee to be established (1) An association must establish a committee to manage its affairs. Note An association's registration is liable to be cancelled if it does not comply with this subsection. (2) The committee must include 3 or more members, each of whom is aged 18 years or more and at least 3 of whom are ordinarily resident in Australia. Note An association's registration is liable to be cancelled if its committee does not comply with this subsection. (3) The committee may exercise such of the association's powers as are not required by this Act or its constitution to be exercised by the association in general meeting.
The 2008 Model Rules dealt in clauses 14 and 15 with the establishment, and subsequent election, of the Association's committee of management. Those clauses provided: 14 Constitution and membership (1) Subject in the case of the first members of the committee to section 21 of the Act, the committee is to consist of: (a) the office-bearers of the association, and (b) 3 ordinary members, each of whom is to be elected at the annual general meeting of the association under rule 15. (2) The office-bearers of the association are to be: (a) the president, (b) the vice-president, (c) the treasurer, and (d) the secretary. (3) Each member of the committee is, subject to these rules, to hold office until the conclusion of the annual general meeting following the date of the member's election, but is eligible for re-election. (4) In the event of a casual vacancy occurring in the membership of the committee, the committee may appoint a member of the association to fill the vacancy and the member so appointed is to hold office, subject to these rules, until the conclusion of the annual general meeting next following the date of the appointment. 15 Election of members (1) Nominations of candidates for election as office-bearers of the association or as ordinary members of the committee: (a) must be made in writing, signed by 2 members of the association and accompanied by the written consent of the candidate (which may be endorsed on the form of the nomination), and (b) must be delivered to the secretary of the association at least 7 days before the date fixed for the holding of the annual general meeting at which the election is to take place. (2) If insufficient nominations are received to fill all vacancies on the committee, the candidates nominated are taken to be elected and further nominations are to be received at the annual general meeting. (3) If insufficient further nominations are received, any vacant positions remaining on the committee are taken to be casual vacancies. (4) If the number of nominations received is equal to the number of vacancies to be filled, the persons nominated are taken to be elected. (5) If the number of nominations received exceeds the number of vacancies to be filled, a ballot is to be held. (6) The ballot for the election of office-bearers and ordinary members of the committee is to be conducted at the annual general meeting in such usual and proper manner as the committee may direct.
There were significant differences between the 2014 Constitution and the 2008 Model Rules. For present purposes, it is sufficient to identify four of them.
First, under the 2014 Constitution the management committee members were to hold office until the next annual general meeting, but such meetings were to be held, despite their name, only every three years. This contrasts with the one year tenure of committee members under the 2008 Model Rules.
Second, under the 2014 Constitution the office bearers were to be elected by the members of the committee once they had been elected. Under the 2008 Model Rules (so it was contended by the plaintiffs) the election of office bearers is direct.
The third difference concerned the number of committee members. One clause in the 2014 Constitution provided that the committee was to consist of at least four office bearers, and eight other members. Another clause provided that the number of committee members (including, it would seem, the office bearers) was to be nine. On any view the number was different from the seven prescribed by the 2008 Model Rules.
The fourth difference was that the 2014 Constitution provided for the election of the committee to take place "under" a supervisory group of members. The supervisory group was to be selected by the existing committee three months prior to the election, and its makeup notified to the public. It was to consist of at least ten members "elected from the community". The precise role of the supervisory group was not clearly specified but it included signing off on the election ballot paper. The Constitution also provided that the result of the vote should be "announced" by the supervisory group "and their decision is final". All of this contrasts with the provisions of the 2008 Model Rules, which provide in general for the existing committee to be responsible for the conduct of the election of the new committee, and the secretary to be responsible for certain functions such as receiving nominations.
The plaintiffs' Statement of Claim pleads that in these and other respects the elections for the committee of the Association have been conducted in accordance with the 2014 Constitution, and not in accordance with the 2008 Model Rules. In particular, the plaintiffs allege that since 2014, there have only been two elections, one in 2014 (which was apparently the meeting of 28 June to which I have already referred) and one in July 2017. The plaintiffs allege that at each meeting a total of nine members of the committee were purportedly elected, and there was no direct election of office bearers, the office bearers being purportedly chosen by the committee following the purported election. The plaintiffs plead, as a consequence, that the purported elections were all invalid and the membership of the committee is, in law, vacant.
The plaintiffs' application in their notice of motion sought the appointment of a receiver to the Association, with specific conferrals of power, and directions, to ensure that the receiver could conduct an election. The powers and directions extended to ensuring that the register of members was complete and accurate, so as to permit all members of the Afghan community who wished to participate in the vote to do so.
The plaintiffs' proposed receiver was Guy Baxendale. Mr Baxendale is a registered liquidator whose firm is in the Central Business District of Sydney.
I have already referred to Mr Ebrahimi's evidence about the events of 2014. Mr Ebrahimi also gave evidence about the impending election. A copy of the election announcement of 18 May was annexed to his affidavit.
The announcement stated that anyone who was a member of the Association was entitled to be elected or appointed as a committee member. It provided an email address where interested members could obtain nomination forms, stating that the nomination needed to be signed by two other members.
The announcement went on to state that an election supervisory group would be appointed to "take control of the election process and the counting of votes". The announcement invited nominations from interested members to join the group, and indicated that nomination forms could be obtained from the email address to which I have already referred.
The announcement stated that nominations for election to the committee and for the election supervisory group were due fourteen days prior to the election, and therefore had to be lodged by 26 June. I note in passing that under the 2014 Constitution the supervisory group was to be appointed at least three months in advance of the election.
Mr Ebrahimi also annexed to his affidavit copies of the nomination forms both for election to the committee and appointment to the election supervisory group nomination form. Both forms required, among other things, that the person nominating must state that he or she had read and understood "the constitution". As foreshadowed in the announcement, the form for election to the committee contained space for the signature of the candidate and for two sponsoring members of the Association.
The nomination forms were sent to Mr Ebrahimi on 10 June by Mansur Mansuri. Mr Mansuri is one of the active defendants, and is the de facto secretary of the Association. In his covering email, Mr Mansuri stated that if Mr Ebrahimi wished to nominate, he must first become a member of the Association. It seems that the records of the Association did not show Mr Ebrahimi as a member. Mr Ebrahimi in his affidavit stated that he had been a member of the Association "since 1987" (the date of incorporation of the Former Association) and had never resigned nor been expelled.
In support of the application, an affidavit was also read from the eighth plaintiff, Dr Mohammad Aymal. He was likewise advised by Mr Mansuri that should he wish to nominate for the election he would need to be a member. His affidavit stated that he had been a member of the Association since 2001 (this must also be a reference to the Former Association) and had never resigned or been expelled.
The defence of the active defendants states that in 2014 and 2017 there were general meetings of the Association at which committee elections were held. The defence admits that there were no other committee elections. It alleges, however, that at the annual general meeting for the year ended 30 June 2018, which took place in February 2019, a number of individuals were elected to the committee, or as office bearers. Among the individuals allegedly elected was Mr Mansuri, as secretary. The defence pleads that even if the committee members purportedly elected in 2017 no longer hold office, those elected in February 2019 do.
The defence admits that both in 2014 and 2017 a committee of nine was elected, and that the office bearers were chosen by the committee members rather than being elected directly. On the latter point, however, the defence alleges that in both the 2014 and 2017 elections the candidates campaigned on "tickets" which specified the offices that the candidates would fill, and the offices were in fact filled by the elected candidates after the elections.
The defence pleads that despite any invalidity of the 2014 Constitution, and despite the admitted (or otherwise established) divergences between the way in which the elections were conducted and the 2018 Model Rules, the existing de facto committee members and office bearers continue to hold office. I take it that the defendants' contention is that non-compliance does not necessarily result in invalidity: compare Project Blue Sky Inc v Australian Broadcasting Authority (1998) 194 CLR 355 at [93]. In addition the defence calls in aid statutory provisions.
First, the defence relies upon AIA 2009, s 28(4). That provides: (4) A committee member's acts are valid despite any defect in his or her appointment.
Next the defence relies on the Corporations Act 2001 (Cth), s 1322, which the AIA makes applicable to incorporated associations: AIA 2009, s 96; Associations Incorporation Regulation 2016 (NSW), r 18. In particular s 1322(2), provides that a "procedural irregularity" does not invalidate a "proceeding under the Act", which, in its application to incorporated associations, means a "proceeding under" the AIA.
The defence alleges that the constitution of the Former Association contained provisions similar to the 2014 Constitution, and in particular a provision for the committee to hold office for three years. The defence alleges that the practice of conducting elections every three years goes back to the time of the Former Association, the suggestion being, that the effect of the default provisions in the AIA were not appreciated when the Association was registered as a replacement following the Former Association's deregistration. The defence goes on to allege that some of the plaintiffs were themselves involved in the conduct of past elections, including as members of the supervisory group.
The defence pleads that s 28(4) and s 1322(2) overcome any defects in the election of the existing de facto committee of management. The defence also pleads laches or acquiescence as an answer to the plaintiffs' claims.
In opposition to the plaintiffs' application, an affidavit dated 9 July was read from Mr Mansuri. Mr Mansuri was born in Afghanistan and came to Australia in 2000. He worked as a volunteer on the building of the mosque.
Mr Mansuri was one of the committee members purportedly elected at the 2014 election general meeting, and again at the 2017 election general meeting. He stated that he was elected as secretary (in place of the previous secretary, who wished to retire from that role) at the annual general meeting, held in February 2019.
Mr Mansuri gave evidence about the way in which the Association operates. He stated that the Association has no paid employees, and all of its activities and administration, including by its committee members, are undertaken on a voluntary basis.
According to Mr Mansuri, the main languages spoken in Afghanistan are Farsi and Pashto. Farsi is spoken by about three-quarters of Afghans and Pashto by about one quarter, although many Pashto speakers also speak Farsi. According to Mr Mansuri, the same pattern exists in the Afghan community in Australia, with the addition that many of the younger members of the community also speak English. The activities and administration of the Association involve a mixture of Farsi, Pashto and English.
Mr Mansuri stated that he, and, he believed, his colleagues, had been unaware of the requirements of the 2018 Model Rules until recently. His evidence was that the procedure laid down in the 2014 Constitution had been followed, at least in general terms.
Mr Mansuri stated that prior to the election general meeting in 2017, he became aware that the Association had no register of members. Prior to that date, the assumption had been that anyone who was a member of the Afghan community would be entitled to vote. Presumably members of the community were well enough known to each other for there to be no dispute about this. Mr Mansuri stated that for the purposes of the 2017 meeting members were enrolled and this was used as the basis for the Association's register of members.
Mr Mansuri stated that a great deal of effort had been spent on preparing for the election scheduled for 12 July. The supervising body had been selected and briefed; and a Covid-19 plan had been prepared and special arrangements had been made to allow the meeting to take place in compliance with the current social distancing requirements.
Mr Mansuri stated that in his opinion the appointment of Mr Baxendale as receiver would be unsatisfactory. Obviously the cost would be unwelcome. Anyone in charge of the Association's affairs also needed to be able to speak Farsi (and ideally Pashto), and to have some standing in the Afghan community. Mr Mansuri added that in his opinion the community would not accept someone who is not a Muslim being in control of a mosque and in particular being in control of the burial of Muslims.
Counsel for the plaintiffs contended that the current de facto committee was not elected in accordance with the 2008 Model Rules. In any event, even if the 2017 election had been valid, the committee members' tenure would have ended at the next annual general meeting, in February 2019. The committee of the Association was therefore vacant and a receiver needed to be appointed to fill the vacuum and conduct an election.
Counsel submitted that the proposed election on 12 July was not a solution. In order to conduct the election action needed to be taken by the Association. Under the 2008 Model Rules such action had to be taken by the committee on the Association's behalf, but there was no validly elected committee. Any election conducted under the auspices of the de facto committee would be invalid for that reason alone. Furthermore, the evidence showed that the intended election would not be conducted in compliance with the 2018 Model Rules.
Counsel for the active defendants did not dispute that an election was necessary. Counsel also accepted that, at least once the 2014 Constitution was removed from the Register, the election would need to be conducted in compliance with the 2008 Model Rules. But counsel contended that the de facto committee were still in office, or at least Mr Mansuri was. There was therefore sufficient power in the de facto committee, or Mr Mansuri, to conduct the election. In any event, the 12 July election would meet the requirements of the 2018 Model Rules and the committee which would emerge from it would hold valid office.
In support of these contentions, counsel submitted that on its true construction, cl 14 of the 2008 Model Rules does not require direct election of the office bearers, and, even if it does, cl 15 does not require nominations to specify the office for which a candidate is nominating. Counsel also submitted that all of the defects in the 2017 election, and any defect in the proposed election on 12 July, would be overcome by s 28(4) and s 1322(2). Counsel also referred to s 1322(4), which is also referred to in the defence, but that provision requires a validating order to be made by the Court, and no formal application for such an order, which would, I think, require the filing of a cross-claim, has been made. Counsel did not develop the pleaded laches and acquiescence defences as answers to the plaintiffs' application.
Counsel also advanced discretionary reasons for refusing the plaintiffs' application. Counsel referred to the decision of Young CJ in Eq in Countouris v Kallos [2008] NSWSC 840, to the effect that, in the case of a company, a court is usually reluctant to interfere with the exercise of shareholders' rights in general meeting. Counsel submitted that members' democracy is at least as important for an incorporated association. He pointed out that in the present case the preparation for the 12 July meeting was well advanced and the application had only been made at a late stage. Counsel submitted that I should not impose the cost and cultural difficulties associated with a receivership on the Association and should instead let the meeting go ahead so that democracy could prevail.
I accept that in general the Court is reluctant to interfere with members' democracy. But in circumstances where the plaintiffs were alleging that the whole election would be invalid, I needed to balance the Court's reluctance to interfere against the risk that the plaintiffs' contention would ultimately be vindicated and the whole election process would have to be re-run later.
There is no doubt that under the 2008 Model Rules it is the existing committee which is collectively responsible for the conduct of the election of the new committee, although the secretary is responsible for receiving the candidates' nominations. Therefore even if Mr Mansuri validly held office as secretary, the election process would not be saved unless the rest of the committee were also validly in office.
The path to that conclusion is not an easy one. The Court would have to accept that the registration of the 2014 Constitution had some sort of indefeasible effect while it remained on the Register. The alternative, and arguably preferable, views are that the Register is purely evidentiary; or that, once an order is made rectifying the Register, that order operates ab initio: compare Akierman Holdings Pty Ltd v Akerman [2019] NSWSC 1486 at [244]-[245] and [327].
Alternatively, the Court would have to accept that s 28(4) or s 1322(2) kept the committee members purportedly elected in 2017 in office, even if their initial election was invalid, and despite the apparently automatic vacation of office at the following annual general meeting. In this regard, it should be noted that the Corporations Act equivalent of AIA s 28(4), s 201M, does not apparently apply where a director's office is vacated and the director is not thereafter purportedly reappointed: Morris v Kanssen [1946] AC 459 at 471 and also Grant v John Grant & Sons Pty Ltd (1980) 82 CLR 1 (Kitto J). Whether these and other contraventions of the 2008 Model Rules could be described as merely "procedural" defects in the holding of office by the de facto committee members is also debatable, to say the least.
I am not sure that it is possible simply to pass over these matters for the purposes of counsel's alternative argument that the election on 12 July would comply with the 2008 Model Rules. But in any event I consider that doubtful. By the time the application came on for hearing, the time for nominations specified in the announcement for nominations had already closed. The terms of the announcement and the nomination forms reflected the understanding that the 2014 Constitution would be applicable. In particular they did not permit a candidate to nominate for election as an office bearer. They also imposed a requirement, not found in the 2008 Model Rules, for each nomination to be supported by two existing members. Indeed it appears that persons who consider themselves to be members and wish to participate had not been recorded on the register at all.
I was not satisfied that these problems could be solved by allowing members of the community to join before or at the meeting, and by ensuring that there was a separate ballot for the election of office bearers at that meeting, as counsel for the active defendants suggested. The possibility that, had the 2008 Model Rules been complied with, there might have been other nominations or the vote might have turned out differently, could not be excluded.
I emphasise that for the purposes of determining the plaintiffs' application for the appointment of a receiver, I did not need to, and did not, decide the questions about what the terms of the 2008 Model Rules require and whether the de facto committee members remain in office. Those questions remain open for final determination in due course.
But on the evidence before me, I considered that there was (at the lowest) a real likelihood that the proposed election on 12 July would turn out to be invalid. I considered that the risk was sufficiently substantial to justify replacing that process with an election conducted by a receiver. In my view, frustrating as that may have been for members of the community, it was a price worth paying to ensure that, whatever the membership of the committee which ultimately emerges, there will be no doubt as to their ability to take the affairs of the Association forward.
Having reached these conclusions, I was keen to avoid the cost and possible cultural difficulties involved in appointing the plaintiffs' nominated receiver, Mr Baxendale. I suggested that there might be a member of the community with sufficient standing who would be acceptable to both sides for appointment as receiver to conduct the election. I adjourned the proceedings to the following day to see whether this was possible.
At the resumed hearing on 10 July, I was informed that the plaintiffs and the active defendants had agreed a group of four members of the community to act collectively as the Receivers for the purpose of conducting an election. Counsel for the active defendants presented some proposed orders providing for their appointment. The proposed orders also provided for the powers of the Association required to update the register of members and to conduct the election to be conferred on the receivers.
The orders also provided for an election timetable. The receivers were to send out a notification within seven days (that is, by 10 July 2020) of the orders the Court had made. The receivers would call for and accept nominations, and then conduct the election on Sunday 2 August 2020.
Counsel for the plaintiffs did not fully accept the proposed orders. There were four areas of dispute. (1) Counsel pressed for declarations that the offices were vacant. (2) Counsel also pressed for orders restraining the purported members of the committee and officers of the Association from conducting the election which had been proposed for 12 July. (3) Counsel submitted that the receivers should have power not only to conduct the election but also power over all of the property of the Association. In particular, counsel stated that the Association operates a website, and raised the possibility that it could otherwise be used for partisan purposes in the course of the campaign. (4) Counsel argued that the timetable in the proposed orders was too short. Instead, counsel suggested the receivers should consider for themselves how long it would be necessary to take the steps required to conduct the election and when it could best be conducted. The orders could then provide for the election to be held on a date fixed by the receivers, or, alternatively, the Court could fix the date.
As to counsel's first point, I was not prepared to make a declaration of vacancy at this point. As I have already stated, it was not necessary for me to come to any final conclusion on the invalidity questions posed and they remain open for further argument in due course.
Nor did I think it necessary to make an order restraining the individual defendants from conducting the election on 12 July. It was quite clear from the attitude of counsel for the active defendants that they accepted that as a result of the Court's decision to appoint receivers the proposed election on 12 July would not go ahead.
As to counsel's third point, if a professional receiver is appointed to a body corporate, the orders would usually provide for him or her to have control over all of the body's property. But I was concerned that the four receivers who had been agreed upon by the parties were not professionals and might well have taken on the position on the understanding that all they would be required to do was to conduct the election.
The parties are to be commended on their agreement to have the Receivers conduct the election, and the receivers are to be commended for accepting the task of doing so in the interests of the community. I did not think it appropriate to burden them further with tasks associated with the administration of the Association's property unless it was really necessary to do so.
For these reasons, I was prepared to allow the active defendants to remain in effective control of the Association's property until the election is held. But it is important that everybody understands that this is only a temporary expedient.
As I see things at the moment, the active defendants may well lack the legal power to act as the committee of management. All of the steps they have taken with respect to the management and administration of the Association's property, and any further steps which they take between now and the election, will be subject to scrutiny. Restraint will be necessary and the active defendants will need to be careful not to take any action which might be partisan or otherwise controversial. They should see themselves as occupying caretaker roles.
There will also be liberty to apply so that if any issue does arise (for example, with respect to the use of the Association's website in the election), it will be open to the plaintiffs to move at short notice for orders and to bring the matter back before the Court. If the de facto committee do behave in a partisan fashion, the Court will not require much persuasion to put the affairs of the Association in the hands of an independent receiver, despite the cost and despite the cultural and religious difficulties which that may cause.
As to the fourth point, I thought it desirable to have a timetable for the receivers so as to give them something to work towards. But should the receivers consider that they need more time to conduct the election or to conduct any preliminary steps, they will be able to use the liberty to apply to approach the Court for an extension. The first order of business for the receivers upon appointment will obviously be to decide whether the timetable which has been set is feasible.
Finally, I should record that, on the arguments presented before me, I thought that the better view of the interpretation of clauses 14 and 15 of the 2008 Model Rules is that they do indeed provide for the separate nomination and separate direct election of each of the office bearers of the Association. It will of course be open to members of the community to organise themselves into groups and form tickets, but the nomination must be for one office or another, and it must also be open to individuals, whether aligned with a ticket or not, to nominate for any of those specified positions. I have not decided this issue finally, and it is conceivable that I might ultimately change my mind. But in the meantime that is the basis on which the receivers should proceed.

At a glance

Court

Decision date

Before

Source

Judgment (5 paragraphs)

Parties

Legislation Cited (7)

Cases Cited (4)