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[2000] VSC 341
Supreme Court of Victoria
2000-09-01
Eames J
Original judgment source is linked above.
TESTATORS FAMILY MAINTENANCE - will - application by adult daughter - substantial estate - residue held on discretionary trust for benefit of daughter during lifetime, and the remainder to form perpetual charitable trust - whether testatrix made adequate provision for proper maintenance and support - whether threshold test met - daughter suffering mental illness - testatrix not having accurate knowledge of extent of illness - daughter an invalid pensioner living in rental accommodation - whether daughter should have provision for purchase of home - relevance of autonomy, independence and control of funds by daughter - further provision ordered - section 91 Administration and Probate Act 1958
"Bipolar mood disorder is a notorious condition in terms of the sufferers mismanaging their financial affairs, especially in states of mania where profligate overspending is not uncommonly encountered. However, these particular features have not been present with Ms Richard, largely because her illness has been reasonably well controlled. In fact, Ms Richard impresses as a thoroughly competent money manager, she being a person of quite limited financial resources but she seems to have utilised her meagre income most prudently, as best I can judge. It is certainly my view that, at this time, there could be no doubt that she is legally competent."
"91. Power of the Court to make maintenance order (1) Despite anything in this Act to the contrary, the Court may order that provision be made out of the estate of a deceased person for the proper maintenance and support of a person for whom the deceased had responsibility to make provision. (2) The Court must not make an order under sub-section (1) in favour of a person unless - (a) that person has applied for the order; or (b) another person has applied for the order on behalf of that person. (3) The Court must not make an order under sub-section (1) in favour of a person unless the Court is of the opinion that the distribution of the estate of the deceased person effected by - (a) his or her will (if any); or (b) the operation of the provisions of Part 1, Division 6; or (c) both the will and the operation of the provisions - does not make adequate provision for the proper maintenance and support of the person. (4) The Court in determining - (a) whether or not the deceased had responsibility to make provision for a person; and (b) whether or not the distribution of the estate of the deceased person as effected by - (i) the deceased's will; or (ii) the operation of the provisions of Part 1, Division 6; or (iii) both the will and the operation of the provisions - makes adequate provision for the proper maintenance and support of the person; and (c) the amount of provision (if any) which the Court may order for the person; and (d) any other matter related to an application for an order under sub-section (1) - must have regard to - (e) any family or other relationship between the deceased person and the applicant, including the nature of the relationship and, where relevant, the length of the relationship; (f) any obligations or responsibilities of the deceased person to the applicant, any other applicant and the beneficiaries of the estate; (g) the size and nature of the estate of the deceased person and any charges and liabilities to which the estate is subject; (h) the financial resources (including earning capacity) and the financial needs of the applicant, of any other applicant and of any beneficiary of the estate at the time of the hearing and for the foreseeable future; (i) any physical, mental or intellectual disability of any applicant or any beneficiary of the estate; (j) the age of the applicant; (k) any contribution (not for adequate consideration) of the applicant to building up the estate or to the welfare of the deceased or the family of the deceased; (l) any benefits previously given by the deceased person to any applicant or to any beneficiary; (m) whether the applicant was being maintained by the deceased person before that person's death either wholly or partly and, where the Court considers it relevant, the extent to which and the basis upon which the deceased had assumed that responsibility; (n) the liability of any other person to maintain the applicant; (q) the character and conduct of the applicant or any other person; (p) any other matter the Court considers relevant."
"I do not think, generally speaking, that the courts, when they have referred to `moral duty' have really intended to do more than suggest that the court ought to do what it supposed that the testator would have done if he had known and properly appreciated all the circumstances of the case."
"There are no rigid rules; the question whether adequate provision has been made for the proper maintenance and support of the adult son must depend on all the circumstances - that is, on all the facts that existed at the date of the death of the testator, whether the testator knew of them or not, and all the eventualities that might at that date reasonably have been foreseen by a testator who knew the facts."
"The fact that a payment may produce an incidental effect going beyond maintenance and support cannot put it beyond power, I think, if its substantial character is that of a provision for maintenance and support."
[1] See Stott v Cook (1960) 33 ALJR 447 at 448, per Kitto J; Singer v Berghouse (No2); (1994) 181 CLR 210 at 208-210 [1994] HCA 40; (1994); 68 ALJR 653 at 656-7.
[2] Unreported 30 August 1995, Ormiston J.
[5] (1921) 41 NZLR 218 at 220-221.
[8] [1979] HCA 2; (1979) 143 CLR 134 at 147-8.
[10] Unreported, Supreme Court, 5 October 1993, Hayne J.
[11] [1984] VicRp 13; [1984] VR 161 per McGarvie J.
[12] [1957] HCA 45; (1957) 97 CLR 1 at 19.
Richard
AXA Trustees Ltd [2000] VSC 341
(1960) 33 ALJR 447
(1994) 181 CLR 210
(1956) 95 CLR 494
(1979) 143 CLR 134
(1992) 29 NSWLR 405
(1957) 97 CLR 1