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[1999] VSC 274
Supreme Court of Victoria
1999-08-20
Byrne J
Original judgment source is linked above.
"In an interlocutory proceeding, the hearsay rule does not apply to evidence if the party who adduces it also adduces evidence of its source."
Moreover, O. 33 R. 2(1) of the Federal Court Rules permits hearsay to be led in circumstances where the exclusion would cause undue delay or inconvenience. It further states that this indulgence is applicable only to evidence other than evidence on an issue at trial. "Trial" is defined in O. 1 R. 4 to include "any hearing other than an interlocutory hearing".
"The newspaper rule is not capable of applying directly to proceedings under Pt 3, r. 1. The respondent to an application under Pt 3, r. 1 is not, as such, a defendant in a defamation action. Such an application is not an interlocutory proceeding in such an action. One very powerful reason for denying that the rule has a direct application to the present class of preliminary discovery is that the object of such an application is to ascertain the identity of an informant so that the applicant may sue him. The object of an interlocutory application in a defamation action is to obtain evidence, admissions or better particulars with respect to the issues for trial in the action. If the only object of such an application were to identify the defendant's source of information with a view to bringing an action against the informant, the purpose of the application would be foreign to the proceedings. Yet that purpose is the very object of an application for preliminary discovery. On the other hand the policy considerations which underlie the existence of the rule are unquestionably factors to be taken into account in the exercise of the judicial discretion that Pt 3, r. 1 confers. If it were otherwise, the making of orders for preliminary discovery would undermine the status and strength of the rule in its application to defamation actions at the interlocutory stage. However, to say that the policy considerations behind the newspaper rule are relevant in an application for preliminary discovery does not mean that an applicant will fail unless he makes out a case of special circumstances. What an applicant must show is that the order sought is necessary in the interests of justice; in other words, the making of the order is necessary to provide him with an effective remedy in respect of the actionable wrong of which he complains."
The dictum relied upon in Levis v McDonald is contained in the words which I have emphasised. Again, the context makes it clear that the High Court was not expressing a view that a Pt. 3 R. 1 application was not an interlocutory application generally.
"...proceedings that are not final, usually dealing with procedural problems that arise in preparing a case for trial, but including proceedings for injunctions pending the trial of an action."
On that basis, his Honour concluded that the evidence was offered on the trial of an application for a permanent injunction which is in the nature of a final order. Accordingly, hearsay was not receivable.
"The distinction between final and interlocutory proceedings and orders has been much discussed, often in the context of the question whether an appeal lies as of right or only with leave. In Hall v The Nominal Defendant [1966] HCA 36; (1966) 117 CLR 423 at 444, Windeyer J, after referring to authorities, said that: a final order is one which finally disposes (subject only to appeal) of an action or an existing dispute between the parties. Although the formula by which the distinction is expressed might be agreed, there may be difficulty in applying it. In one sense, even a decision which all would acknowledge to be interlocutory, finally disposes of the particular issue the subject of that decision, subject to any right of appeal. For example, a decision that particular documents must or need not be discovered is an interlocutory order. Yet it finally disposes of the particular dispute between the parties over discovery, subject to any appeal brought with leave. Sometimes interlocutory orders have been referred to as orders which preserve the status quo pending a final hearing and determination. But again that is only a commonly encountered class of interlocutory order. An order resolving a dispute over discovery or interrogatories, for example, although clearly interlocutory, is not of that kind. Common to the two kinds of interlocutory order just referred to is the fact that they contemplate that the parties will be before the same court again when a decision will be made which will determine the parties' jural relations after which they will not be before that court again on the same matter. In the present case, what is sought is an injunction permanently restraining the exercise of a right to depose a potential witness apparently given to the applicants pursuant to a United States statute. It may be that if the right was given by this Court's Act or Rules as an incident of the procedures governing the present proceeding it would be proper to regard an order resolving a dispute over the exercise of the right as interlocutory. But the right here in question, although given by United States law for the purpose of assisting foreign or international tribunals and `any interested person' ... is not an incidental part or adjunct of these proceedings and is independent and self standing."
I infer from this passage, first, that his Honour saw the leave to appeal cases, such as Hall v The Nominal Defendant, as setting out the test for him to apply. Second, from the examples given, it is clear that his Honour had in mind the dictum of Cotton LJ in Gilbert v Endean which I have quoted above in [6]. Third, the test which his Honour applied to characterise an application as interlocutory is that it does not determine "the parties' jural relations", that is, their rights and obligations in the principal proceeding. They must return to the court for the determination of these ultimate issues. While the application before his Honour might have been interlocutory if brought in the US Court, it was not so in the Federal Court of Australia because the parties sought no further relief in that court.
"'Business': means conduct of the authorised area distributorship using the system of marketing the Products under the `FAI Security Group' name and logo and using the Marks, the Intellectual Property, methods, techniques, information, know how and other relevant Intellectual Property used or owned by FAI Security Group."
"... about the Business and FAI Security Group's methods of business, including details of customers of the Business, the contents of any Manuals issued by FAI Security Group, as well as any trade secrets or any part of Intellectual Property (including business plans, budgets, customer or data bases, terms of trade and details of suppliers to the Business."
In addition, the directors of an Area Distributor are obliged to enter into an agreement with FAI under which they, too, are bound by the same conditions as those in the distribution agreement.
"(a) any list of any person or entity that has purchased a home security alarm system branded the `FAI Home Security Package' or `SecurityGuard I' or SecurityGuard II' that the Respondent has or has had or is likely to have had in its possession; (b) all documents including, but not limited to, correspondence, notes and records brought into existence by the Respondent, or which were sent to or from the Respondent, which refer to, or which were created or derived from, any list of any person or entity that has purchased a home security alarm system branded the `FAI Home Security Package' or `SecurityGuard I' or `SecurityGuard II' which the Respondent has or has had or is likely to have had in its possession."
FAI Home Security Pty Ltd
Price [1999] VSC 274
"Proceedings vary so widely, covering so many different situations, that comprehensive definitions of `interlocutory' and `final' are probably impossible. But the essence of the distinction seems to me to lie in the connotation, implicit in the phrase, that in general `interlocutory proceedings' are proceedings other than the trial of the action or the equivalent hearing in the case of an originating summons or other originating process. The trial of an action or the equivalent stage of other originating processes would, in general, be regarded as `final,' but even here there may be exceptions, depending on the nature of the claims in the proceedings. For example, the trial of a Norwich Pharmacal Co. v. Customs and Excise Commissioners [1973] UKHL 6; [1974] A.C. 133 type of action may be an exception, and there may well be others. Broadly that is how, as it seems to me, the terms `interlocutory' and `final' in this context would be understood by lawyers."
Marks J at [1990] VR 461-2 agreed that the order was interlocutory, applying the test in Licul v Corney [1976] HCA 6; (1976) 180 CLR 213:
(1997) 75 FCR 36
(1973) 3 ALR 414
(1966) 117 CLR 423
(1976) 180 CLR 213
(1981) 147 CLR 246
(1990) 20 NSWLR 588
(1988) 165 CLR 346
(1997) 73 FCR 241
(1996) 64 FCR 55
(1987) 1 QdR 221
(1994) 53 FCR 125