Background, primary decision, issues, procedure
- The respondent to this appeal (the applicant in the primary proceedings) (the lot owner) owns three lots in a 618-lot multi-storey strata scheme known at least in part as UniLodge on Broadway in Ultimo, a suburb on the edge of the city of Sydney, NSW. The appellant (the respondent in the primary proceedings) is the owners corporation (OC) of the scheme.
- In the primary proceedings filed 8 August 2023 the lot owner claimed lost rental income from two of the three lots for periods 11 January to 28 December 2021 (50 weeks and one day) for one lot and 12 March 2021 to 21 February 2022 for the other lot (49 weeks and three days). Rental for one lot was $420pw; rental for the other lot was $500pw. The decision not to rent out was made after receipt of a notice in mid-January 2021 that extensive remedial works to the common property exterior and to a specific common property matter in the lot owner's lots required access for a stated period of six weeks from commencement of the works.
- The lot owner said that hoardings installed by the OC for fascia repairs had been "preventing" the lot owner from renting the lots for much longer than the specified period and that the OC "has continuously failed to install and remove the hoardings on the dates promised to do so".
- The OC said that the claims were for damages for alleged breach of duty under s 106(5) of the Strata Schemes Management Act 2015 (NSW) (SSMA) and were filed out of time under s 106(6) because the lot owner first became aware of the loss allegedly suffered as a result of the OC's alleged breach of its strict duty under s 106(1) to maintain and repair the common property which included the façade more than two years before the proceedings were filed. The OC said that the date of first awareness was either the date of notice in mid-January 2021 or May to June 2021, based on emails from the lot owner complaining about the hoardings and their effect on the rentability of the lots.
- In the primary decision made 19 October 2023 the primary member accepted the lot owner's argument, apparently on a basis reflective in part of the reasoning of the Appeal Panel in Tezel v Owners SP 74232 [2022] NSWCATAP 149 (10 May 2022), that first awareness occurred and therefore time under SSMA s 106(6) began to run from when the rental lost could be quantified which was the completion of the works. Accordingly, the proceedings were filed within time (being from December 2021 and February 2022) whichever lot was in question.
- The primary member said, relevantly:
"12. I do not accept that [mid-January 2021] is when time for the applicant to have commenced. It could not possibly have been in position to know of its loss. However, the notice of works had a consequential effect on the applicant causing its loss. But is not the commencing point for time to run. In fact the applicant advised the respondent [OC] in June 2021 of its potential claim for damages on going loss of rent then. The respondent was aware of the claim at that time.
13. I accept that the time ran from the quantification of the alleged loss, in February 2022 and I find that the application is accordingly within time."
- The primary decision post-dated the delivery of the NSW Court of Appeal's decision, on 6 March 2023, in Owners SP 74232 v Tezel [2023] NSWCA 35, which reversed the Appeal Panel's decision. The decision is discussed below.
- The primary member found at paras 14 and 15 of the primary reasons (PR) that there were long-running delays by the builder in carrying out the remedial works with "constant failure of delivery within specified time periods to the inconvenience of the applicant". The OC was found to have breached its duty by failing "to manage the building works of the common property in a proper manner to ensure that the works on the common property were completed timely and efficiently thereby causing damage of an economic loss to the applicant".
- The primary member at PR para 16 further found that the lot owner's choice not to re-let the lots (once notified of the imminent works) was based on the previous strata manager's promises "of commencement of works to be undertaken … hence the significant delays not anticipated by the applicant".
- The primary member found, at PR paras 17 to 26, as follows: the OC would have taken 12 weeks to complete the works directly affecting the relevant two lots the subject of claim if acting in an efficient manner (with four months being a more than generous time to complete the works efficiently, we assume meaning overall); delays beyond the efficient time for the two lots were to be compensated which for their lot owner meant 38 weeks for each unit (taking a global approach); the compensation took into account the lot owner's duty to mitigate by taking a lower rental in the circumstances (which included the consequences of the covid epidemic and the works); that lower rental was found to be $350pw for each lot.
- The OC appealed only on the limitation point; there was no other ground of appeal from either party.
- On 1 December 2023 the OC was granted leave for legal representation on condition that it did not seek recovery of its legal costs under orders in the proceedings. The lot owner was granted leave to be represented by its sole director who we were told was a beneficial owner of the lots in question. At the appeal hearing she was supported by her father who was a solicitor but not present in that capacity - with no disrespect, we do not know the father's experience in respect of strata matters.
- At the appeal hearing the OC did not object to further evidence sought to be led by the lot owner but said that it was irrelevant if its argument succeeded that the entire claim was out of time.
- It was not sought to be argued by the parties that s 41 of the NCAT Act operated so as to empower the Tribunal to extend time for the lot owner's application under SSMA s 106(6) to date of filing, and that such extension should be granted in the present case on the principles in Jackson v NSW Land and Housing Corporation [2014] NSWCATAP 22 at [22]. There is authority in the Appeal Panel that such power exists: Hua Nan Trading PL v Owners SP 32396 [2023] NSWCATAP 66 at [47]-[76] and [89]-[94] and generally [43]-[109]. That decision was delivered on the same day, 6 March 2023, as the NSW Court of Appeal upheld an appeal from the Appeal Panel's decision in Tezel, in Owners SP 74232 v Tezel [2023] NSWCA 35.
- The Tribunal is empowered under s 41 of the NCAT Act to extend time of its own motion. In the circumstances just outlined we considered it in accord with the Tribunal's duties, including to accord procedural fairness, in s 38 of the NCAT Act, to afford the parties an opportunity to make written submissions on this topic based on the existing evidence.