By notices of motion filed on 25 March 2019 in each of proceedings 2017/294069 and 2018/52431 (together, the Representative Proceedings) the fourth to four hundred and fifty seventh defendants (Deloitte) seek to strike out those parts of the plaintiffs' Amended Joint Statement of Claim (AJSC) that plead a claim against Deloitte.
The two proceedings are brought on behalf of investors in DSHE Holdings Limited (Receivers and Managers Appointed)(In Liquidation) (DSH). DSH traded as "Dick Smith", a well-known electronics retailer. It was floated on the Australian Securities Exchange (ASX) in December 2013. It was placed into voluntary administration by its directors on 4 January 2016 and was placed into liquidation on 25 July 2016. Deloitte was retained by Dick Smith Sub-Holdings Pty Limited (DSSH), an intermediate holding company in the DSH Group, and later DSH to audit the financial statements of DSSH for the financial year ending 30 June 2013 (FY13) and the financial statements for DSH for the financial years ending 30 June 2014 (FY14) and 30 June 2015 (FY15).
In broad terms, the plaintiffs allege that the practices and decisions made by DSSH concerning the provisioning of inventory and by DSH concerning both rebates and the provision of inventory meant that the financial statements of DSSH for FY13 and the financial statements for DSH for FY14 and FY15 were not prepared in accordance with Australian Accounting Standards. That led to the financial statements of DSSH for FY13 and of DSH for FY14 and FY15 not giving a true and fair view of DSH's financial position and performance. It is alleged that Deloitte's failure to identify those matters, and representations by Deloitte contained in its audit reports that the financial statements did present a true and fair view of DSSH's and DSH's financial position, meant that Deloitte failed to conduct its audits in accordance with applicable auditing standards, failed to exercise reasonable care and skill, and engaged in misleading and deceptive conduct in contravention of various statutory provisions.
Findlay v DSHE Holdings Limited [2019] NSWSC 394 | Case summary | Zoe
Deloitte contends that the pleading against it is defective because it fails to plead the case against it with sufficient specificity. In making that submission, it relies heavily on the judgments given by Ward CJ in Eq in Hastie Group Ltd (In Liq) v Bourne [2017] NSWSC 709 and Smith v Australian Executor Trustees Ltd [2017] NSWSC 1406, where her Honour set out in some detail what needed to be included in the pleadings considered in those cases.
In my opinion, the decisions in Hastie and Smith are not of great assistance in resolving the issues in this case, turning as they did on the particular facts and pleadings in those cases.
The critical issue in cases such as the present one where a strike out application is brought is whether the pleading gives fair notice of the case to be made against the other party at trial so as to minimise the risk of injustice resulting from surprise. As Ward CJ in Eq pointed out in Smith at [73], the pleadings have a critical role to play in ensuring that that requirement is satisfied. However, it also needs to be borne in mind that these proceedings are being managed together with proceedings in the Commercial List and that other techniques are available and used by the Court to ensure that no party is caught by surprise. They include, where appropriate, orders for the provision of particulars, orders for the service of evidence in chief, including expert evidence well in advance of a hearing and orders for the exchange of lists of issues.
Against that background, it is possible to turn to the pleading in this case. The claim against Deloitte occupies approximately 100 pages of a pleading which in all comprises approximately 300 pages (including annexures). It is divided into eight Parts. Part F.1 sets out some background. Part F.2 pleads the relevant accounting and auditing framework, including the obligation on Deloitte under s 307A of the Corporations Act 2001 (Cth) (the CA) to conduct its audits in accordance with the Auditing Standards in force under s 336 of the CA. It also identifies the relevant Auditing Standards. Part F.3 pleads the contents of the relevant Auditing Standards and the obligations imposed on Deloitte by those standards in undertaking the audits for FY13, FY14 and FY15. Part F.4 provides a definition of the term "Reasonable Auditor" used in the pleading. Part F.5 pleads the representations said to have been made by Deloitte in its audit reports. Part F.6 pleads Deloitte's conduct in relation to the audit in each relevant year. Part F.7 pleads the various contraventions said to arise from that conduct. Part F.8 pleads causation, loss and damage. In essence, it is pleaded that but for Deloitte's conduct the relevant financial statements would either have been corrected or Deloitte would have issued qualified audit opinions in respect of them. It is pleaded that had the FY13 financial statements been corrected or a qualified audit opinion issued in respect of them, DSH would not have floated and been listed on the ASX and Group Members in the Representative Proceedings would not have acquired their shares.
Deloitte's attack on the pleading is primarily focussed on Parts F.6 and F.8. It contends that both Parts fail to identify with sufficient particularity what Deloitte ought to have done but did not do. It is sufficient to consider the pleading in relation to FY13. The pleading in respect of other years raises similar issues. It is also convenient to start with Part F.6.
The plaintiffs allege that Deloitte failed to act as a "Reasonable Auditor" (as defined in the pleading) in three respects. First, it failed to obtain sufficient appropriate audit evidence in respect of the assumptions and methodology applied by management in determining inventory provisions. Second, it failed to properly determine materiality. Third, it failed to adjust the warranty sign on liability to zero. It is pleaded in para 444 of the AJSC that each of those failures meant that Deloitte:
(a) did not conduct the FY13 Audit in accordance with the Auditing Standards;
(b) did not conduct the FY13 Audit in accordance with Deloitte's auditing obligations as pleaded above at Part F.2;
(c) did not exercise reasonable care and skill in performing the FY13 Audit;
(d) did not have reasonable grounds for believing that the audit evidence Deloitte obtained to carry out the FY13 Audit was sufficient and appropriate to provide a basis for its audit opinion;
(e) did not have reasonable grounds for the opinion that the FY13 Financial Statements were in accordance with the CA, including:
(i) giving a true and fair view of the Group's financial position as at 30 June 2013 and of its performance for the period ended on that date; and
(ii) complying with the Australian Accounting Standards and the Corporations Regulations 2001.
Deloitte's criticism of the pleading focuses on the pleading in relation to inventory.
In para 427 of the AJSC, the plaintiffs plead that Deloitte knew or ought to have known of DSH's failure to write down or to make a provision against the carrying value of inventory and of DSSH's inventory management and accounting policies. Paragraphs 427(a), (b) and (c) give particulars of why it is said Deloitte knew the relevant facts. Paragraph 427(d) pleads why it is alleged that Deloitte ought to have known the relevant facts. In substance that paragraph pleads that a Reasonable Auditor:
1. Would have recognised inventory as a high area of risk;
2. Would have designed appropriate testing and sought further information to ascertain the inventory practices adopted by management;
3. Would have evaluated whether DSSH's assumptions and methodology with respect to inventory provisioning were appropriate; and
4. As a result, would have ascertained the inventory practices adopted by management.
The plaintiffs give some additional particulars of those allegations, although it is doubtful that those particulars advance matters substantially.
Paragraphs 428 of the AJSC pleads in effect the FY13 audit report did not express the opinion that the inventory practices adopted by management needed to be disclosed in the FY13 financial statements or that those practices caused the FY13 financial statements to be materially misstated. Paragraph 429 pleads that the practices needed to be disclosed, and that adoption of the practices meant that the FY13 financial statements did not give a true and fair view of the financial position and performance of DSSH and the DSH Group, were not prepared in accordance with the Australian Accounting Standards and were materially misstated.
Paragraph 430 pleads that Deloitte failed to take various steps it should have taken. Those steps include:
(a) failed to obtain a sufficient understanding of the assumptions and methodology applied by DSSH management in determining inventory provisions, including by failing to apply an adequate level of professional scepticism to the information produced by DSSH, and the assumptions and methodology applied by management in determining inventory provisions in the FY13 Financial Statements (ASA 200, paragraphs 7, 15, A18-A22; ASA 540, paragraphs 8, 18);
(b) having determined that there was a significant risk of material misstatement in respect of inventory provisions in the FY13 Financial Statements, failed to perform substantive procedures that are specifically responsive to that risk, including for the purpose of obtaining sufficient appropriate audit evidence in respect of the assumptions and methodology applied by management in determining inventory provisions in the FY13 Financial Statements (ASA 330 paragraphs 21, A1, A4, A19; ASA 500 paragraphs 6, A1-A3, A10, A14-A15);
(c) failed to design and implement adequate testing of the age of stock and the appropriateness of the obsolescence percentages by reference to stock turnover, volume of stock on hand, and broader industry factors in order to obtain reasonable assurance as to whether the inventory Practices and Effects complied with Australian Accounting Standards (ASA 300 paragraph 21, A1, A4, A19);
(d) by reason of the failures pleaded in sub-paragraphs (a)-(c) above, failed to gather sufficient appropriate audit evidence in order to enable Deloitte to express an opinion on whether the assumptions and methodology applied by management in determining the provision in respect of inventory in the FY13 Financial Statements complied with AASB 102 …
The references at the end of each of those paragraphs are references to the Auditing Standards that it is alleged Deloitte failed to comply with in committing the pleaded failures.
A number of other failings are pleaded in para 430 to be derivative from the failings pleaded in paras (a) to (d). They include:
(h) failed to perform adequate audit procedures to evaluate whether the overall presentation of the financial report was in accordance with the applicable financial reporting framework (ASA 330 paragraph 24) and to evaluate whether the assessments of risks of material misstatement at the assertion level remained appropriate (ASA 330 paragraph 25).
(i) failed to require management to account for the carrying value of inventory in accordance with Australian Accounting Standards;
(j) failed to quantify or estimate the extent of the misstatement in the FY13 Financial Statements as a result of the Inventory Practices and Effects [that is, the inventory practices adopted by management] …
Paragraph 431 pleads that:
In the premises, Deloitte failed to act as a Reasonable Auditor.
I accept that the pleading is not entirely satisfactory. The difficulty with it is that the pleading of knowledge and constructive knowledge are confused with the pleading of conduct that is said to involve a breach of duty. The case against Deloitte has as its starting point the allegation that the FY13 financial statements did not comply with the Australian Accounting Standards because of the failure to write down or make provision against the carrying value of inventory. Details of why that is said to be so are set out in Section C of the pleading. No issue is taken with the pleading of that Section. The case against Deloitte is then put in two ways.
First, it is alleged that Deloitte knew of the practices adopted by management. If that is right and if those practices did not comply with Australian Accounting Standards and if that non-compliance was material (which is pleaded to be the case in para 429), it seems to follow that Deloitte breached its duties as auditor either by failing to require the financial statements to be corrected or by qualifying its audit opinion.
Second, if Deloitte did not know the actual position, it is alleged that that is because it failed to carry out appropriate audit enquiries. Some particulars of what enquiries Deloitte ought to have carried out are to be found in the pleading of constructive knowledge (para 427(d)) and the particulars to that paragraph. However, the principal allegations are to be found in para 430. The critical paragraphs appear to be paras 430(b) and (c). What is alleged is that:
1. Deloitte ought to have "recognised that inventory provisioning was an area of high risk for DSSH, given that the nature of the consumer electronics market is such that there is an ongoing risk of inventory obsolescence" (to quote from para 427(d)(i));
2. Having come to that appreciation, Deloitte failed to perform appropriate procedures that were specifically responsive to that risk and failed to design and implement adequate testing of the age of stock and the appropriateness of the obsolescence percentages by references to stock turnover and the other matters identified in para 430(c).
As I have said, a number of plainly derivative breaches are pleaded. The only exception is the breach pleaded in para 430(h). The failure to perform "adequate audit procedures" referred to in that paragraph appears to be a reference back to the failures previously pleaded. But that is not plain from what is said in the paragraph. On its face, the reference to a failure "to perform adequate audit procedures to evaluate whether the overall presentation of the financial report was in accordance with the applicable financial reporting framework" could be a reference to any type of failure unconnected with provisioning in respect of inventory. However, that cannot be what is intended; and it seems to me that any lingering ambiguity could be resolved by an appropriate request for particulars.
Deloitte's complaint with this pleading is that it does not identify what it is Deloitte ought to have done. For example, it does not identify the type of testing Deloitte should have undertaken. Nor, for example, does it identify the extent of the misstatement in the accounts that Deloitte ought to have identified.
I do not accept that criticism. In my opinion, the case that Deloitte must meet emerges sufficiently from the pleading so that it will not be caught by surprise. To take the examples just referred to, Deloitte knows that it needs to consider the requirements of the Auditing Standards that have been identified by the plaintiffs and consider the question whether any testing it did in relation to provisioning met those standards. Similarly, for the purposes of understanding the case it must meet, it is not necessary for Deloitte to know what provision the plaintiffs say ought to have been made. It is sufficient that they know (which is obvious from the pleading) that the provision would have been sufficiently large to cause the accounts to be corrected or qualified because the misstatement was material.
The likelihood is that, assuming that the plaintiffs are correct and the Auditing Standards required Deloitte to make enquiries or conduct testing concerning DSSH's policies in relation to provisioning to determine whether those policies were appropriate, there were a number of different types of enquiry or testing that Deloitte could have undertaken. In my opinion, it is not necessary for the plaintiffs to specify precisely what enquiries and testing Deloitte ought to have undertaken; and indeed such a requirement runs the risk of unreasonably narrowing the plaintiffs' case. It would be sufficient for the plaintiffs to prove that Deloitte did not undertake any enquiries or testing of the type required by the Auditing Standards. In those circumstances, their case should not fail because they were required to identify the precise enquiries and testing that Deloitte should have undertaken, but were unable to prove that enquiries and testing of those specific types were necessary to comply with the relevant Auditing Standards.
The timetable in the case makes provision for both the plaintiffs and Deloitte to serve expert evidence in relation to the claims against Deloitte, and there is every reason to think that both will do so. Following the service of expert evidence, the experts will be required to meet to attempt to narrow the issues between them. They will be required to prepare a joint report setting out the matters on which they agree and disagree and brief reasons for their disagreement. The likelihood is that the experts will give evidence concurrently and that for the purpose of their concurrent evidence the parties will be required to prepare an agenda for their evidence. Through that process, the issues between the parties will be narrowed further. That is not to suggest that that process is a substitute for adequate pleadings. However, it needs to be borne in mind in determining what is required of the pleading.
As I have said, Deloitte also takes issue with the pleading of causation because it is said not to contain a proper articulation of what Deloitte would have done in the counterfactual. I do not accept that submission. The claim is that the matter would have been raised with management, that either the accounts would have been corrected or Deloitte would have qualified its audit report, and that in either case DSH would not have been floated. In my opinion, it is not necessary for the pleading to be more precise than that. Deloitte is put on notice clearly that the case it must meet is that it would have raised the matter in a way with management that would either have led to changes in the accounts or a qualified audit report. I do not see why the pleading needs to be any more precise than that.
As I have said, it is not suggested that different issues are raised by the pleading in respect of other years. The pleading perhaps is not as clear as it might be. But, for the reasons I have given, I have concluded that the case that Deloitte must meet emerges sufficiently from it, and for that reason I do not think that it should be struck out.
It follows that the notices of motion filed on 25 March 2019 in each of proceedings 2017/294069 and 2018/52431 should be dismissed.
I will hear any application for costs at a time fixed with my Associate.
[2]
ANNEXURE A (FIFTH TO FOUR HUNDRED & FIFTY SEVENTH DEFENDANTS)
5. Brett Douglas Streatfeild
6. Sneza Pelusi
7. James Patrick Hickey
8. Alastair Banks
9. Tara Cathy Hili
10. Paul Jeremy Klein
11. Frank Scott Farrali
12. Christopher Donald Noble
13. Alec Paul Bash Insky
14. George Nicholas Kyriakacis
15. Roan Rolles Fryer
16. Stuart Johnston
17. Kaylene O'Brien
18. Craig Patrick O'Hagan
19. Leanne Karamfiles
20. Neil Graham Smith
21. Demostanies Krailis
22. David John Lombe
23. Christian John Biermann
24. Jonathan Paul
25. Michael James Clarke
26. Roger Jeffrey
27. Rachel Andrea Foley-Lewis
28. Franco Claudio Santucci
29. Michelle Robyn Hartman
30. Matthew Christopher Saines
31. Francis Thomas
32. Robert Basker
33. Alan Eckstein
34. Donal Graham
35. Andrew Raymond Hill
36. Patrick McLay
37. Paul Bernal Liggins
38. David Ocello
39. Paul Scott Holman
40. Paul Robert Wiebusch
41. Murray Peck
42. Julie Michelle Stanley
43. John Bland
44. Timothy Carberry
45. Alvaro Ramos
46. Graeme John Adams
47. Suzanne Archbold
48. Tim Richards
49. Timothy Geoffrey Maddock
50. Xenia Delaney
51. Reuben Saayman
52. Ronaldus Lambertus Van Beek
53. Liesbet Ann Juliette Spanjaard
54. Christopher John Richardson
55. Martin Harry Read
56. Mark Reuter
57. Stuart Thomas Ciocarelli
58. Paul Wayne Hockridge
59. Vikas Khanna
60. Paul Thomas Carr
61. Weng Yen Ching
62. Rodger Stewart Muir
63. Mark Cover
64. Robert Hillard
65. Michael John Lynn
66. Gaile Anthea Pearce
67. Isabelle Emilienne Lefrevre
68. Phillip Andrew Roberts
69. Stuart Alexander Rodger
70. Paul Leonard Wensor
71. Claudio Cimetta
72. Simon Tarte
73. Stephen Charles Gustafson
74. Geoffrey William Cowen
75. Geoffrey Gill
76. Steven John Simionato
77. Jason John Handel
78. Declan O'Callaghan
79. Michael Andrew Kissane
80. Kurt Proctor-Parker
81. Richard Davies Wanstall
82. Johan Simon Duivenvoorde
83. Benjamin John Shields
84. John Meacock
85. Ian Michael Turner
86. David Harradine
87. Muhunthan Kanagaratnam
88. Marc Philipp
89. Kamlee Anne Coorey
90. Hugh William Mosley
91. Paul Masters
92. David Shane Egan
93. Alison Margaret Brown
94. Stavroula Papadatos
95. Damien Tampling
96. Alexandra Jane Spark
97. Monica Ellen Campigli
98. Craig Peter Mitchell
99. Robert John McConnel
100. Alyson Rodi
101. Andrew Charles Price
102. Mark Hadassin
103. Anthony James Robinson
104. Garry Ian Millhouse
105. Ashley Graham Miller
106. Craig Stephen Smith
107. Margaret Lynne Pezzullo
108. Adam Barringer
109. Campbell James Jackson
110. Jason Charles Crawford
111. Kevin Michael Russo
112. Adele Christine Watson
113. Neil Anthony Brown
114. Gordon James Thring
115. Brett William Greig
116. Steven James Shirtliff
117. Robert Donald Collie
118. Spyros Kotsopoulos
119. Austin John Scott
120. Jenny Lyn Wilson
121. Peter John Bars
122. Elizma Bolt
123. Stephen Thomas Harvey
124. Fiona Lea Cahill
125. Jonathan Mark Schneider
126. Michael McNulty
127. Katherine Louise Howard
128. Juliet Elizabeth Bourke
129. Peter Gerard Forrester
130. Carl Jonathan Gerrard
131. Jody Michelle Burton
132. Rachel Frances Smith
133. Peter Martin Rupp
134. Helen Elena Fisher
135. Geoffrey Ronald Sincock
136. Nicholas Harwood
137. John Clement Malcom Randall
138. Todd Kayle Fielding
139. Geoffrey Bruce Stalley
140. Russell Bradley Norman Mason
141. Paul Leon Rubinstein
142. Andrew Ignatius Muir
143. Lisa Barry
144. Alfred Alan Nehama
145. Michael Paul Stibbard
146. Paul Childers
147. Angelo Karelis
148. Sarah Caroline Woodhouse
149. Richard John Hughes
150. Christopher Robert Masterman
151. Robin Poison
152. Megan Joy Field
153. Christopher Guy Nunns
154. Clare Helen Harding
155. Simon Cook
156. Stephen Carl Tarling
157. Leslie Coleman
158. Samuel James Vorwerg
159. Helen Hamilton-James
160. Coert Grobbeiaar Du Plessis
161. Stephen George Stavrou
162. Steven Christopher Cunico
163. Mark Ekkel
164. Soulla McFall
165. Leigh Matthew Pieroni
166. Mark Colin Woodley
167. Stephen James Healey
168. Sandeep Chadha
169. Margaret Clare Bower
170. Anna Victoria Crawford
171. Robert Howard Dowling
172. Greg Janes
173. Colin Mckay Methven Scott
174. Richard Mark Simes
175. Dharmalingum Shunmugam Chithiray
176. Nicole Marie Vignaroli
177. John Giannakopoulos
178. Vaughan Neil Strawbridge
179. Judith Anne Donovan
180. Nicole Wakefield
181. Paula Teresa Capaldo
182. Michael Rath
183. Karen Rachel Stein
184. Brett Todd
185. Julian Craig Dolby
186. Robert Kim Arvai
187. Catherine Jane Hill
188. Richard Michael Thomas
189. Timothy John Gullifer
190. Peter James Pagonis
191. Michael Damon Cantwell
192. Joseph Frank Galea
193. Nicolette Louise Ivory
194. John Leotta
195. Darren James Hall
196. Stephen Huppert
197. Elma Von Vielligh-Louw
198. Michael Anthony Kennedy
199. Stuart James Alexander
200. Yi Mei Tsang
201. Christopher Wilson
202. Joshua David Tanchel
203. Tendal Sitenisiyo Mkwananzi
204. Richard Nigel Raphael
205. Jacqueline Ann Clarke
206. Rodney James Whitehead
207. Heather Park
208. John Lethbridge Greig
209. Adrian Charles O'Dea
210. Grant Cameron
211. Gregory Couttas
212. Steven Allan Hernyl
213. Gary John McLean
214. Jonathan Ma
215. SuzieGough
216. Mark Douglas Ian Allsop
217. Jennifer Anne Exner
218. Ryan Quintin Hansen
219. Jamie Brian Hamilton
220. David Mark Hill
221. Jason Bruce Dunnachie
222. John Christopher McCourt
223. Gerhard Vorster
224. David John Boyd
225. Andrew Kingsley Johnstone-Burt
226. Dwayne Barrie Sleep
227. David Black
228. Gerard Michael Meade
229. Francis Patrick O'Toole
230. Tony Garrett
231. Danny Rezek
232. Mark Goldsmith
233. David Watkins
234. Patrick Broughan
235. Jeremy Drumm
236. Michael John Whyte
237. Mark Andrew Stretton
238. Weng Wee Ching
239. Robert Malcolm Spittle
240. Marisa Orbea
241. Frances Rita Borg
242. David Barrie Brown
243. David Sherwin McCloskey
244. Philip Walter Teale
245. Jan Hein Alexander Alperts
246. Katherine Anne Milesi
247. Kevin Kiazim Nevrous
248. Andrew Paul Annand
249. Carl Richard Harris
250. Philip Malcolm Moore Hardy
251. Derek Rodney Bryan
252. Gregory Gyorgy Janky
253. David John Redhill
254. Guillaume Johannes Swiegers
255. Peter Ronald Ryan
256. Brennan Ursula
257. Fiona Dawn Craig
258. Sarah Lane
259. George Stathos
260. Richard Adam Young
261. Marc Hofmann
262. Brad Joel Pollock
263. Mark Justin Kuzma
264. Warren Green
265. Stuart Osborne
266. Garry Lance Bourke
267. Andrew Vaughn Griffiths
268. Adam Powick
269. Margaret Dreyer
270. Timothy Bryce Norman
271. David McCarthy
272. Neil Pereira
273. Michael Robert Gastevich
274. Elizabeth Ann Brown
275. Lakshman Kumar Gunaratnam
276. Monish Paul
277. Alexander Collinson
278. Bruce John Williamson
279. Luke Bramwell Houghton
280. Aldrin Anthony De Zilva
281. Neil McLeod
282. Gerard Lucien Belleville
283. Michael Kaplan
284. Mark David Irving
285. Alison Lorna White
286. Haiderali Hussein Hussein
287. Martyn Charles Barrett Strickland
288. Caroline Jane Bennet
289. Christopher Robert Campbell
290. Gary Peter Doran
291. Mark Steven Wright
292. Peter Matruglio
293. John Koutsogiannis
294. Selwyn Peter D'Souza
295. Keith William Skinner
296. Clive Charles Alan Mottershead
297. Karen Lynette Green
298. Jason Mark Thome
299. Andrew Stuart Christopher Reid
300. Mark Richard Weaver
301. Matthew Robert Broadfoot
302. Michael Mauro De Palo
303. Peter Arthur Caldwell
304. Tracey Con Dous
305. Shelley Rae Nolan
306. Ian Grant Levi
307. Grant Arthur Hyde
308. Timothy Francis Nugent
309. Andrea Csontos
310. Geoffrey Colin Lamont
311. Christopher John Nicoloff
312. Craig Maxwell Bryan
313. Peter Madden
314. Jeremy Jurriaan Walton Cooper
315. Neil Robert Cussen
316. Robert Southern
317. Andy Peck
318. Colin Radford
319. Hendri Mentz
320. Robert Nguyen
321. Shinji Tsutsui
322. Philippa Simone Dexter
323. Timothy Fleming
324. Cynthia Hook
325. James Campbell Down
326. Kate McDonald
327. Stephen John Coakley
328. Keith Francis Jones
329. Serg Duchini
330. Stephen James Reid
331. Max Andreas Persson
332. Graham Mott
333. Anthony John Viel
334. David Joseph Murray
335. Richard Antony Jamieson
336. Bradley James Burt
337. Anthony Goroslav Buntic
338. Paul Gerard Fogarty
339. Jamie Christopher Gatt
340. Geoffrey Ian Roberts
341. Melissa Jayne Cabban
342. Matthew Fraser
343. Thomas Fredrick Viljoen
344. Julie Christine Crisp
345. Paul Bernard Riley
346. Salvatore Algeri
347. Ross Ian Jerrard
348. Avi Sharabi
349. Ian Geoffrey Sanders
350. Dale McCaauley
351. lain Maxwell Gerrard
352. David Hobbis
353. Scott Conrad Bailey
354. Stephen Gregory Brown
355. Ian Ross Harper
356. Shashi Vicknekumeran Sivayoganathan
357. Jowita Gartlan
358. Mark Ingham
359. Viswa Phani Kumar Padisetti
360. Ian Charles Thatcher
361. Ian Andrew Trevorah
362. Dennis Leslie Moth
363. Jacques Louis Van Rhyn
364. Paul Swinhoe
365. Greg Fitzgerald
366. Steven Alexander Hallam
367. Stuart Lynn Black
368. Stephen Woosnam
369. Andrew John Culley
370. Stephen James Ferris
371. Timothy Arbuckie
372. David Amis Rumbens
373. Matthew James Williams
374. Jason Frederick Bender
375. Patrick Lane
376. Martin Paul Langridge
377. Caithlin Mary McCabe
378. Simon Alexander Wallace-Smith
379. Adrian Clyde Batty
380. Tapan Parekh
381. Masaaki Mark Nakamura
382. Roger Geoffrey McBain
383. Graeme John Hodge
384. Rick Shaw
385. Marina Ruth Stuart
386. Tom Christopher Imbesi
387. Eric Angelucci
388. Harvey Christophers
389. John Kingsley Rawson
390. Mark Richard Sercombe
391. Phillip Kravaritis
392. Gary Christie
393. Wayne Edward Walker
394. John Womack
395. Peter Grainger
396. Samantha Louise Lewis
397. Ashley Jonathon King
398. Peter Francis Williams
399. Alexander Aitken
400. Timothy Gordon Biggs
401. Ian McCall
402. Johannes Laubscher Venter
403. Roberto Dimonte
404. Alan Gordon Weeks
405. Ian John Breedon
406. Peter Michael Roberson
407. Michael David Nelson
408. Lindsay James Stanton
409. Craig Paul Johnson
410. Timothy Riordan
411. Anthony James Cipriano
412. Phil Hopwood
413. Dai-Trang Le Duncanson
414. David Jonathan Graham
415. Andre Spnovic
416. William Harold Wardrop
417. David Erskine Thompson
418. David Kyffin Willington
419. Stephen Mark Holdstock
420. Dean John Grandy
421. Harold Scott Payne
422. Jean-Marie Abi-Ghanem
423. Fraser Ross
424. Roberto Krizman
425. Caroline McGlashan
426. William Robert McAinsh
427. Osamu Uchimura
428. Glendon Moss Sanford
429. Simon James Lester
430. Stephen James Jones
431. Kristen Jay Wydell
432. John Guthrie Hood
433. Paul Martin Radici
434. Frank Klasic
435. Mark John Pittorino
436. David Anthony Cooper
437. Matthew Sheerin
438. Tony Brain
439. Henry John Kidd
440. Matt Gerald Tengu Whitesky Kuperholz
441. Gordon Pattison
442. Branko Panich
443. Julian Christopher Cheng
444. David William Pring
445. Peter Andre Jovic
446. Craig Goldberg
447. Bruce Robert Dungey
448. Dean Robert Edward Kingsley
449. David Alan Watson
450. Bernard Spencer Gild
451. Graham John Newton
452. Dwight Murray Hooper
453. Michael Rosendorfer
454. Richard Roy Porter
455. John George Azarias
456. Donna Maree Carey
457. Christopher Paul Cass
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Decision last updated: 11 April 2019