Mr Shah's response to the Commission's application
- In orders made on 26 May 2016, we directed any party electing to make an application for costs to file and serve its application and any submissions in support within 14 days. We also directed any party opposing the other's application for costs to file and serve submissions in reply (see Shah at [60]).
- No application for costs was received from Mr Shah within the time frame set out above. However, in submissions in reply to the Commission's application, Mr Shah not only opposed that application but also applied for his own costs. In the alternative, he sought an order that each party bear their own costs.
- The authorities have considerately identified the problems associated with the practice of filing submissions without, or outside, leave: see for example, NT Power Generation Pty Ltd v Power and Water Authority [2004] HCA 48; (2004) 219 CLR 90 at p 192; Bale v Mills [2011] NSWCA 226; 81 NSWLR 498 at pp 513, 514; Eastman v Director of Public Prosecutions (ACT) (2003) 214 CLR 318 at p 330. For these reasons we have decided to disregard Mr Shah's application for costs and will confine our consideration to Mr Shah's alternative submission, that each party should bear their own costs.
- Mr Shah argues that there was no legislative requirement that the Commission appear in these proceedings and it elected to do so in the knowledge that it may incur costs as a result. He submits that in these circumstances the appropriate order is that each party should bear its own costs.