Sorbara v DJ & AJ McCallum Pty Ltd [1998] VSCA 71
[1998] VSCA 71
At a glance
Source factsCourt
Court of Appeal (Vic)
Decision date
1998-10-14
Before
ORMISTON, PHILLIPS and KENNY, JJ.A.
Source
Original judgment source is linked above.
Judgment (76 paragraphs)
LANDLORD AND TENANT - Retail tenancies - Motel premises - Meaning of "retail premises" - Meaning of "floor area" - Retail Tenancies Act 1986 (No. 106), ss.3, 21.
- The definition of "retail premises" and the exclusion from that definition of premises with a "floor area" exceeding 1,000 square metres in s.3 of the recently repealed Retail Tenancies Act ("the ") has caused much difficulty. It caused difficulty because, although it was clear that the various protections afforded to tenants under the were primarily intended to benefit those engaged in small businesses, the form of the exception has had varying effects for that purpose, depending on the nature of the businesses carried on. Attempts to give effect to Parliament's intentions have led to a series of inconsistent, or partly inconsistent, decisions by judges of the Supreme Court, each valiantly attempting to create order out of chaos by reading into the words used some meaning which would give consistent effect to the legislature's intentions, when applied to a variety of situations. This is the first occasion the definition and the exception have been considered by an appellate court and the solution to the matters raised has caused me much concern, for seemingly any answer given might prove of general application, inasmuch as we were assured in argument that the definition and the exception remain the same under the 1998 ("the new Act"). However, although that assurance was literally correct, it omitted reference to s.s.(5) of s.3 of the new Act which states that "in determining the floor area of premises for the purposes" of the new Act, regard should be had to "the guidelines for the measurement of lettable area" to be notified (only) in the Government Gazette by the Minister for Small Business. Anything, therefore, we say as to the meaning of the definition and exception in the former Act must be treated with the greatest care for the purposes of the new Act in that what is said must be tempered by a realisation that, notwithstanding continuing complaints as to the effectiveness of the definition under the former Act, Parliament has now qualified those definitions merely by making an indirect reference to "lettable area", at least for certain purposes in determining the floor area of premises under the new Act; see also s.4 of that Act as to its application.