Shaw v Yarranova Pty Ltd & Anor [2012] VSCA 189
[2012] VSCA 189
At a glance
Source factsCourt
Court of Appeal (Vic)
Decision date
2012-08-16
Before
Hargrave J, Warren CJ
Source
Original judgment source is linked above.
Judgment (19 paragraphs)
- The applicant contended that Beach J erred in not conducting an assessment pursuant to s 91 of the Legal Practice Act 1996 to determine the extent, if at all, that the respondents' solicitors had failed to make the disclosures required under the Act and to then reduce the costs. He said on the leave application that the order for production was wide enough to cover such documents and that as nothing was produced it follows that there had been no requisite disclosure. The respondents submitted that the documents did not fall within the order for production as these were not documents that set out the method by which the respondents' costs had been calculated. The respondents pointed to the fact that the order had been made in the context of a request for 'relevant retainer letters, costs agreements, invoices, proof of payments of invoices and actual costs paid' hence it was not within the contemplation of the respondents' solicitors that disclosure documents were being sought. The respondents contended that the applicant had not claimed that it had been established that there was any failure by the respondents' solicitors to disclose to the respondents any information required under the Act. The applicant's case was that 'if there has been no costs disclosure, the court should conduct an assessment of the costs and reduce them in accordance with s 91 and s 93.'
- Even if there was evidence from which it could be inferred that there had been non-compliance with s 86 of the Legal Practice Act 1996, and assuming that the applicant falls within the description of persons who could apply for an assessment of the respondents' solicitors' bill of costs under s 115(1) of that Act, there had, by the time of this submission before Beach J, been an assessment and a review of all the relevant bills of costs. It was not for Beach J to have undertaken such a task, nor could his Honour have ordered a further assessment except in 'special circumstances.'[39] A complaint by the applicant, as the party who has been ordered to pay the costs of the proceeding, that there may have been non-compliance with the disclosure requirements of the Act, would not in our opinion constitute a 'special circumstance' warranting a further assessment.