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[2023] NSWCA 14
Court of Appeal (NSW)
2023-02-09
Bell CJ, Gleeson JA, White JA, Lindsay J
Original judgment source is linked above.
[Note: The Uniform Civil Procedure Rules 2005 provide (Rule 36.11) that unless the Court otherwise orders, a judgment or order is taken to be entered when it is recorded in the Court's computerised court record system. Setting aside and variation of judgments or orders is dealt with by Rules 36.15, 36.16, 36.17 and 36.18. Parties should in particular note the time limit of fourteen days in Rule 36.16.]
HEADNOTE [This headnote is not to be read as part of the judgment] Ivan Ritossa (the Applicant) and Anthony Ritossa (the First Respondent) are engaged in probate proceedings concerning the three competing wills of their late mother, Maria Ritossa (the Deceased). The principal asset in the estate comprises two adjoining parcels of land in Maroubra (the property) which has remained vacant since the Deceased's death on 30 April 2019 and has been informally and unilaterally managed by the Applicant. The parties disagreed as to the management of the property, particularly as to whether it should be sold or leased and whether a caretaker should have been appointed at a cost to the estate. The First Respondent sought orders pursuant to s 73 of the Probate and Administration Act 1898 (NSW) (the Act) and in the Court's inherent jurisdiction for the appointment of an interim administrator pending determination of the probate proceedings. Those orders were made by Lindsay J (the primary judge) on 10 August 2022. The principal issue raised on the application for leave to appeal was whether the discretion to appoint an interim administrator could only be exercised protectively where it was established that the estate was "in jeopardy". The Court held (Bell CJ, Gleeson and White JJA agreeing), refusing leave to appeal, that: 1. The high bar for leave in relation to an interlocutory, discretionary decision on a matter of practice was not met as there was no issue of principle to which the decision gave rise, no question of public importance and no injustice to the Applicant: [36]-[37] (Bell CJ); [53] (Gleeson JA); [54] (White JA). 2. While the presence of 'jeopardy' may be an instance in which the power to appoint an interim administrator under s 73 of the Act may be exercised, the power is constrained only by the requirement to advance the due and proper administration of the estate in the best interests of the ultimate beneficiaries and judicial glosses should not otherwise be applied to the broad language in which s 73 of the Act is expressed: [39]-[44] (Bell CJ); [53] (Gleeson JA); [54] (White JA). 3. The relationship between the parties, as evidenced by their inability to agree on an interim arrangement and their disagreement as to the management of the property, meant it was well open to the primary judge to appoint an interim administrator of the estate pursuant to s 73 of the Act: [45]-[51] (Bell CJ); [53] (Gleeson JA); [54] (White JA).
Introduction
Factual and procedural context
Section 73 of the Act
The primary judgment
Application for leave to appeal
Consideration
Conclusion
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Ritossa
Ritossa
[1988] HCA 13
[1994] HCA 54
[2005] SASC 477
[2013] QSC 348
(1986) 10 FCR 180
(1988) 165 CLR 268
(2006) 225 CLR 180
(1911) 12 CLR 310
(1992) 174 CLR 178
(2006) 228 CLR 423
(1994) 181 CLR 404
(2003) 217 CLR 92
(2005) 93 SASR 337
(1936) 55 CLR 499
(2013) 82 NSWLR 268
(2017) 95 NSWLR 597
[2006] HCA 45
[2003] HCA 62