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[2000] VSC 363
Supreme Court of Victoria
2000-09-12
ASHLEY, J.
Original judgment source is linked above.
"All actions in which the damages claimed consist of or include damages in respect of personal injuries to any person, shall be commenced within three years next after the cause of action accrued but not after."
It was implicit in the submissions made by all counsel that the cause of action accrued on 9 March 1994.
"(1) Subject to this section, where an Act ... limits the time for - (a) instituting an action ... a court may extend the time so ... limited to such an extent, and upon such terms (if any) as the justice of the case may require. (3) This section does not - ... (b) empower a court to extend a limitation of time prescribed by this Act unless it is satisfied - (i) that facts material to the plaintiff's case were not ascertained by him until some point of time occurring within twelve months before the expiration of the period of limitation or occurring after the expiration of that period and that the action was instituted within 12 months after the ascertainment of those facts by the plaintiff; ... and that in all the circumstances of the case it is just to grant the extension of time. (4) Where an extension of time is sought pursuant to this section in respect of the commencement of an action, the action may be instituted in the normal manner, but the process by which it is instituted must be endorsed with a statement to the effect that the plaintiff seeks an extension of time pursuant to this section. (5) Proceedings under this section may be determined by the court at any time before or after the issue of pleadings."
The writ by which this proceeding was commenced was not endorsed in accordance with subs.(4). That circumstance founded an argument to which I must later refer.
Facts Material to the Plaintiff's Case: The Law and its Application
"The plaintiff ascertained in November 1999 that he was unemployed having lost his job with CSN Australia Ltd. and having no alternative employment."
Further according to the plaintiff, it followed that, the proceeding having been commenced in December 1999, the circumstances fitted both the second limb of the disjunctive qualification set out in s.48(3)(b)(i) as well as the conjunctive requirement imposed by the last portion of that paragraph.
"It is helpful, in undertaking the task of construction of s.48, to have in mind the model provided by the innovative legislation in this field enacted by the Parliament of the United Kingdom in the Limitation Act 1963 ('the 1963 Act'). Section 1 of that Act provided that the period of three years prescribed by the Limitation Act 1939 (U.K.) for bringing a personal injuries action based on negligence, other breach of duty or nuisance (hereinafter collectively referred to as 'negligence') shall not afford any defence to such an action provided, inter alia, that it was proved that the material facts relating to the cause of action were or included facts of a decisive character which were at all times outside the knowledge (actual or constructive) of the plaintiff until a date which satisfied the time prescriptions in the section. Section 7 was an interpretation section which, inter alia, elaborated in some detail the meaning that was to be given to 'material facts', 'facts of a decisive character' and 'knowledge (actual or constructive) of a person'."
"It is quite clear that the South Australian legislature preferred a simpler model to that contained in the 1963 Act. No doubt the broad purpose of the Act was substantially the same, namely, to eliminate the injustice a prospective plaintiff might suffer by reason of the imposition of a rigid time limit within which an action was to be commenced. Section 48(1) confers, subject to the section, a general and unfettered power upon a court to extend the time prescribed by any Act (including the Limitation of Actions Act 1936 itself) or piece of subordinate legislation for instituting an action, or for doing any act in an action or with a view to instituting an action. The wide general power so conferred is limited by sub-s. (3). That sub-section denies to a court the power to extend the time within which an action may be instituted unless it is satisfied of the existence of the circumstances set out in either para.(i) or (ii). The contrast between the matters described in para. (i) and the 1963 Act is significant. The former is not limited to material facts which relate to a cause of action and satisfy the exhaustive enumeration in s.7 of the 1963 Act. The subject-matter of para. (i) is facts which are material to the plaintiff's case, with no attempt to provide any definition of the categories to which such facts must conform. The reference to the plaintiff's case supplies a broader canvas than the reference in the 1963 Act to the cause of action. Unlike the 1963 Act, there is no requirement that the material facts be of a decisive character, no reference to constructive knowledge, no obligation to have used due diligence in seeking to discover at an earlier time the facts in question and no mention of seeking appropriate advice. The effect of the paragraph was described by Bray CJ in Napolitano ((1977) 15 SASR at p.569) in words which we are glad to adopt:
'A plaintiff may still be entitled to ask the Court to extend the time under the section, notwithstanding that he has been supinely inactive and notwithstanding that the material facts might easily have been ascertained earlier and notwithstanding that their nature is not such as to be decisive of the success of the action or even such as to have in his mind weighed down the balance in favour of litigation. All these matters, of course, are relevant to the discretion, and it seems to me that the South Australian Parliament, having made one qualifying condition, which in some cases may not be of great significance, has left all the rest to the discretion of the court.'
In our opinion the Full Court was correct in overruling Cakebread and Raison. There is no warrant for writing into the Act a further qualification that, to attract the operation of s.48(3)(b)(I), there must be some interaction between the material fact and the plaintiff's decision to sue. It is materiality to the plaintiff's case that must be shown. This is a broad general requirement that is capable of satisfaction by objective inquiry. To introduce notions, related to the decision to sue, that would require an examination of the subjective workings of the plaintiff's mind would complicate the court's task and impede rather than advance the purpose of the Act. A fact is material to the plaintiff's case if it is both relevant to the issues to be proved if the plaintiff is to succeed in obtaining an award of damages sufficient to justify bringing the action and is of sufficient importance to be likely to have a bearing on the case."
"I am aware that you are unable to relocate to Dalby and unfortunately this means your last day with CSN Pty. Ltd. will be on 12 November 1999. I have given you three months notice before your tenure ends in order that you may be able to find alternative employment whilst still employed at CSN Pty. Ltd."
"The requirement in subsection (4) that the request for an extension must be endorsed on the originating process does not sit comfortably with the rule, it must be said, where the time limitation is one imposed by the Statute of Limitations or a similar statutory provision. It does not sit comfortably because when the process is issued it is not known whether the statute will be pleaded. It is appropriate, however, where the cause of action has been extinguished and has to be revived. I do not think to much should be made of that anomaly. The purpose of section 48 is to relieve plaintiffs whose actions are out of time, of the hardship resulting from time limitations. Its purpose is ameliorative. It would not accord with that purpose to construe the section as extinguishing causes of action which would not otherwise be extinguished."
43 Robinson, supra, did not involve a choice of law issue. The question, in substance, was whether s.48(4) impacted upon the rule of construction that a provision such as s.36(1) of the Act (see also s.5(6) of the Limitation of Actions Act 1958) bars the remedy but not the right, in which circumstances it is necessary to affirmatively plead a limitation defence. The Full Court of the Supreme Court of South Australia decided that s.48(4) did not have any such impact. Had the provision been treated as going to the jurisdiction of the court, that outcome would not have been possible. I consider that Robinson assists a conclusion that a writ not endorsed in accordance with s.48(4) is not a nullity, and that the court may grant leave to a plaintiff to amend the writ to add an appropriate endorsement.
"... the applicant must establish that the commencement of an action beyond the limitation period would not result in significant prejudice to the prospective defendant."
"... once the legislature has selected a limitation period to allow the commencement of an action outside that period is prima facie prejudicial to the defendant who would otherwise have the benefit of the limitation."
"... on well established principles an applicant must satisfy the court that grounds exist for exercising the discretion in his or her favour. There is an evidentiary onus on the prospective defendant to raise any consideration telling against the exercise of the discretion."
"A material consideration (the most important consideration in many cases) is whether, by reason of the time that has elapsed, a fair trial is possible."
McHugh J explained the rationale of limitation periods this way, at 551:
"The discretion to extend time must be exercised in the context of the rationales for the existence of limitation period. For nearly 400 years, the policy of the law has been to fix definite time limits (usually six but often three years) for prosecuting civil claims. The enactment of time limitations has been driven by the general perception that `[w]here there is delay the whole quality of justice deteriorates'. (21) Sometimes the deterioration in quality is palpable, as in the case where a crucial witness is dead or an important document has been destroyed. But sometimes, perhaps more often than we realise, the deterioration in quality is not recognisable even by the parties, Prejudice may exist without the parties or anybody else realising that it exists."
"The effect of delay on the quality of justice is no doubt of the most important influences motivating a legislature to enact limitation periods for commencing actions. But it is not the only one. Courts and commentators have perceived four broad rationales for the enactment of limitation periods. First, as time goes by relevant evidence is likely to be lost (26). Second, it is oppressive, even `cruel', to a defendant to allow an action to be brought long after the circumstances which gave rise to it have passed (27). Third, people should be able to arrange their affairs and utilise their resources on the basis that claims can no longer be made against them (28). Insurers, public institutions and businesses, particularly limited liability companies, have a significant interest in knowing that they have no liabilities beyond a definite period". "Even where the cause of action relates to personal injuries (33), it will be often just as unfair to make the shareholders, ratepayers or taxpayers of today ultimately liable for a wrong of the distant past, as it is to refuse a plaintiff the right to reinstate a spent action arising from the wrong. The final rationale for limitation periods is that the public interest requires that disputes be settled as quickly as possible."
"A limitation provision is the general rule; an extension provision is the exception to it. The extension provision is a legislative recognition that general conceptions of what justice requires in particular categories of cases may sometimes be overridden by the facts of an individual case. The purpose of a provision such as s. 31 is `to eliminate the injustice a prospective plaintiff might suffer by reason of the imposition of a rigid time limit within which an action was to be commenced'. (35) But whether injustice has occurred must be evaluated by reference to the rationales of the limitation period that has barred the action. The discretion to extend should therefore be seen as requiring the applicant to show that his or her case is a justifiable exception to the rule that the welfare of the State is best served by the limitation period in question. Accordingly, when an applicant seeks an extension of time to commence an action after a limitation period has expired, he or she has the positive burden of demonstrating that the justice of the case requires that extension."
* The hardship to the plaintiff if the action is dismissed and the cause of action left statute barred;
* The prejudice to the defendants if the action is allowed to proceed notwithstanding the expiration of the limitation period (in this context I take account of presumption of prejudice and the rationales for limitation periods identified by McHugh J in Brisbane South);
* The extent to which, having regard to the delay, the evidence is likely to be less cogent than if the action had been brought within the time allowed;
* The conduct of the defendants in the litigation;
* The relative importance or unimportance of the facts material to the plaintiff's case which have satisfied the requirement of s.48(3)(b)(i) of the Act;
* Whether the facts material to the plaintiff's case were discovered by contrivance, or artificially, or should be regarded as "genuine".
Reid
AGCO Australia Ltd [2000] VSC 363
(2000) 74 ALJR 1109
(1991) 174 CLR 1
(1987) 163 CLR 628
(1975) 10 SASR 479
(1977) 15 SASR 559
(1995) 65 SASR 307
(1990) 101 FLR 78
(1987) 46 SASR 364
(1997) 188 CLR 114
(1996) 186 CLR 541
(1980) 24 SASR 567
(1988) 52 SASR 237