© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2008] WASC 256
Supreme Court of WA
2008-11-07
Hasluck J
Original judgment source is linked above.
41 On 20 May 2008 the learned commissioner delivered lengthy reasons for decision directed to these issues: Chin v Thies [2008] WADC 71.
After the event and in this appeal, Mr Nicholas Chin made much of having his 'Will deflected' employing a line from the DPP for Northern Ireland v Lynch (1975) 1 All England reports [sic] Lynch v Director of Public Prosecutions for Northern Ireland [1975] UKHL 5; [1975] 1 All ER 913; [1975] AC 653. But if it fell to me to be satisfied on balance, I would not be so satisfied. Since the judgement he has protested much about the duress but there is no evidence of it at or immediately before or even immediately after the time of judgement and the tone and mood of his communication, both to the court and to the respondent at the time of judgement, are far more consistent with a genuine desire to end the litigation and to pay the agreed amount promptly.
The findings I have made from Mr Nicholas Chin's argument in this appeal is that his allegations of duress were an afterthought and a last ditched effort to recover a position that he now regrets. There is much to establish that he and his son freely entered into all aspects of the settlement; that they cooperated and communicated several times during April, May and June 2007 with the respondent and with the registrar to bring it about and that they confirmed it without hesitation. There is no corroborative evidence of disability or duress which could properly displace the position as it now stands. As to both appellants I dismiss the appeal.
81 Previously decided cases concerning writs of certiorari suggests that an arguable case is one that has some prospect of success: Perpetual Trustees WA Ltd v City of Joondalup [1999] WASCA 108.
82 Under the former practice the process of applying ex parte existed in order to enable a party to come before the court quickly and simply. A party proceeding by way of ex parte application bears a most serious responsibility because the court is asked to disregard the usual requirement of hearing the other side: Zucal v Harper [2005] WASCA 76; (2005) 29 WAR 563.
95 In Re Ex Parte Bartholomew [2008] WASC 52 Murray J made the following observations about the making of a review order:
The Magistrates Court Act was proclaimed to come into operation on 1 May 2005 (Government Gazette 31 December 2004 p 7127). In the first matter to come before the court, Thompson v Lane [2005] WASC 281, which was heard and delivered in December 2005, Simmonds J noted that s 36 was clearly intended to take the place of the prerogative writs of mandamus, prohibition and certiorari which, by s 35, may not be directed to a court officer of the Magistrates Court. The term 'court officer' is defined by s 3 to mean a magistrate or other judicial officer.
In Re an Application under the Magistrates Court Act 2004; Ex parte Brecker [2007] WASC 151, Beech J, at [49], held that, consistently with the use of the word 'may' in s 36(4), the powers of this court to make final orders on the hearing of the review were discretionary. At [55], his Honour held that although the review order required the party to whom it was directed to satisfy the court, 'that the act, order or direction should or should not be done or made or set aside,' the onus of persuasion would lie upon the applicant for relief, the party moving the court to make an order under s 36(4).
In Re an Application under the Magistrates Court Act 2004; Ex parte Snook (No 2) [2007] WASC 255, Simmonds J, at [101], expressed the view that at least in a case of denial of natural justice, as was that case, the discretion within was in the nature of a discretion to refuse relief, upon good grounds.
99 In relation to the mandamus, Rich, Dixon and McTiernan JJ made these observations in the leading case of The King v War Pensions Entitlement Appeal Tribunal; Ex parte Bott [1933] HCA 30; (1933) 50 CLR 228:
100 As to other forms of relief, I draw upon certain observations I made recently in Buckland v The Department of Corrective Services [2008] WASC 177 as follows:
Wherever the legislature entrusts to any body of persons other than the superior courts the power of imposing an obligation upon individuals or affecting the legal rights, the courts are inclined to hold that such bodies are required to act judicially, that is to say, they must act within jurisdiction and they will be obliged to observe the rules of natural justice by affording to the party likely to be affected notice of the case against him and an opportunity of replying to it. The requirements of procedural fairness may vary according to the nature of the statutory provisions and the circumstances in the particular case: Kioa v West [1985] HCA 81; (1985) 159 CLR 550, 615, 633; Mills v Hendriksen [2008] WASC 79 at [113] - [114].
If a body required to act judicially falls into error then relief can be obtained via the prerogative writs of certiorari and prohibition. For example, in Hot Holdings Pty Ltd v Creasy (1996) 185 CLR 149 the High Court held that a preliminary decision or recommendation made by a mining warden, if it is one which constitutes a condition precedent to an exercise of power that affects legal rights, will have the requisite legal effect upon rights to attract certiorari.
In the circumstances of that case, since the minister was required to take the warden's recommendation into account, the warden's decision had a discernable legal effect on the minister's exercise of discretion. Hence, certiorari lay to a challenge a decision by a warden to conduct a ballot for the purpose of determining the party entitled to priority in respect of competing applications for a mining tenement.
These principles are also reflected in the decision of the High Court in Craig v State of South Australia [1995] HCA 58; (1995) 184 CLR 163 where it was said at 177 that a body obliged to act judicially falls into jurisdictional error if it mistakenly asserts or denies the existence of jurisdiction or if it misapprehends or disregards the nature or limits of its functions or powers in a case where it correctly recognises that jurisdiction does exist. Further, such a body will exceed its authority and fall into jurisdictional error if it misconstrues the relevant statutory provisions or other instrument and thereby misconceives the nature of the function it is performing with extent of its powers in the circumstances of the particular case. [41] - [44]
114 In Bailey v Marinoff [1971] HCA 49; (1971) 125 CLR 529 Barwick CJ expressed the rule in this way:
115 It has therefore been said that if a judgment is erroneous, but nonetheless correctly expresses the intention of the court, it may be set aside or varied only on appeal: DJL v Central Authority [2000] HCA 17; (2000) 201 CLR 226.
122 The learned author observes that a court may set aside any order made by consent, and intended to carry out an agreement between the parties, upon any ground on which the agreement may be set aside raised in a separate proceeding instituted for that purpose. If judgment was obtained by fraud practised on the court there are three possible courses of action depending on the circumstances; that is, an action may be brought to set aside the judgment; an application may be made in the original action; or an appeal may be taken. An appeal court may order a new trial where fraud in the conduct of the proceedings below is clearly evident. It is not necessary for the plaintiff in a new action to prove the fraud by fresh evidence which was not available to him or her and could not have been discovered with reasonable diligence before the judgment was delivered: McDonald v McDonald [1965] HCA 45; (1965) 113 CLR 529 at 532.
123 It is therefore necessary in cases of this kind for the plaintiffs to establish that they and the court were deceived and that since the trial they have discovered something material in the sense of fresh facts that either in themselves or in combination with previously known facts would prove fraud. It follows from the public interest in the finality of litigation that a party cannot seek to litigate matters that were the subject of earlier proceedings by reliance on evidence on which the party failed at trial: Ridout v O'Brien [2004] WASC 137.
(1994) 14 WAR 158
(2005) 29 WAR 563
(1933) 50 CLR 228
(1985) 159 CLR 550
(1996) 185 CLR 149
(1995) 184 CLR 163
(1971) 125 CLR 529
(2000) 201 CLR 226
(1965) 113 CLR 529
(1992) 8 WAR 400
It is useful, for present purposes, to come to a clear understanding about how s 36(1) and (4) are intended to operate. The provisions are difficult to read because the draftsman has collapsed into two subsections what, in my respectful view, might have been more clearly expressed at greater length in separate provisions.
One thing is clear. I respectfully agree that the section is designed to be a statutory process of review by the Supreme Court of the acts, orders and directions of the Magistrates Court and of the refusal of that court to perform an act, make an order, or give a direction, in proceedings before it. It is designed to replace the formerly available prerogative writs of mandamus, prohibition and certiorari, but s 36(1) is to be read on its own terms and it would be a mistake, in my opinion, to put s 36(1) into the framework of the grounds it would have been necessary to make out to obtain a formerly available form of prerogative relief. That is not to say that it will not be instructive to consider, on a review under s 36, whether the act done, order made, direction given or refusal to do any such thing of which complaint is made, is of a kind and in circumstances which would ground an order in the nature of mandamus, prohibition or certiorari. Section 36(1) makes that inquiry directly relevant to the exercise of the powers on review, in any event. [16] - [20]