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[2003] VSCA 65
Court of Appeal (Vic)
2003-06-03
CALLAWAY, BATT and CHERNOV, JJ.A.
Original judgment source is linked above.
[ 2003] VSCA 65
PRACTICE AND PROCEDURE - Extension of time - Condition that privileged surveillance videotapes be disclosed before hearing improper .
LEGAL PROFESSIONAL PRIVILEGE - Whether privilege waived by listing documents in court book index - Surveillance videotapes of applicant for leave to bring proceedings against employer - Whether, in absence of authority of statute or of valid rule of court, power in judge to require pre-hearing disclosure of tapes to applicant or to prevent tender of tapes, not having been disclosed but being admissible evidence, or their use in cross-examination - Whether R.34A.29 of Ch.I of County Court Rules is such authorisation in event of non-compliance with R.34A.35(4)(d) - Whether , s.134(2DA) and (2DD) or Directions under such authorisation.
exhibiting medical and "other material"[2] upon which the parties intended to rely, an order for discovery by the appellant by categories as well as discovery of all documents on which it sought to rely at trial and all documents injurious to its case or the respondent's case, and an order fixing the proceeding for trial on 15 October 2002. But the presently important order is that numbered 10, by which, so far as material, each party was required to serve a court book on or before 8 October 2002 and file the book on the day of trial, such book to contain the documents specified in Rule 34A.35(4)(a), (b) and (c) of Chapter I of the County Court Rules as well as "a list only of any documents a party intends to tender in evidence or which a party otherwise intends to use at trial[3] pursuant to Rule 34A.35(4)(d)".
"Unless the Court otherwise orders, a court book ... shall contain and contain only - (a) an index of its contents; (b) a copy of the writ or originating motion; (c) a copy of the latest version of any pleadings served ... and particulars of any such pleading ... and any ... order or request by a party for particulars; (d) a list of any documents a party intends to tender in evidence or which a party otherwise intends to use at the trial or at the hearing of the application (as the case requires)."
Paragraph (5), so far as material, requires each party to serve a court book not less than seven days before the hearing of the application and to file it at the commencement of that hearing.
"Surveillance reports and films on which a party intends to rely are not required to be exhibited to an affidavit sworn and served by a party, unless such surveillance reports or films have been shown to any medical practitioner whose report is exhibited to an affidavit sworn and served by that party."
His Honour stated that it was not necessary or appropriate to express a view on the validity of the Practice Note, though he did consider it appropriate to take account of its requirements as well as "issues relating to the disclosure of surveillance material prior to its use in Court and what [effect] that might have on whether justice would be done between the parties at the hearing". He then referred to a statement by Hayne, J., made in the course of argument on an application for special leave to appeal from the decision of the Full Court of the Supreme Court of Western Australia in Boyes v. Colins[8], decrying a suggestion that a party should be able to hold back surveillance film. Whilst acknowledging that it was not appropriate to rely upon statements of justices during argument of special leave applications[9], his Honour said that Hayne, J.'s remark was consistent with the approach of courts in recent times to take surprise and the element of "ambush" out of the litigation process. He stated that provisions of the Accident Compensation Act relating to "serious injury" applications (particularly the s.135A(2DA), (2DC) and (2DD)) and the Ministerial Directions published pursuant to s.135AB made it clear that the parties should make full disclosure of material relied upon at the earliest stages. He referred to Boyes v. Colins, where the Full Court had held that a defendant would not be caused injustice if it were required to produce surveillance videos before trial.
"Taking account of the explanation given by the [appellant's] solicitors for the non-compliance with the order, the lack of any real prejudice that flowed from the delay in complying with the order until 10 or 11 October 2002, and considering whether, in the circumstances, the fair trial of the proceeding [between] the parties would be advanced by disclosure of surveillance material which the [appellant] had indicated it would tender in evidence or otherwise rely upon at the trial, I determined that the leave sought by the [appellant] should only be granted on condition that disclosure of that material first be made to the [respondent] and that otherwise leave should not be granted."
"It is likely, in accordance with decisions relating to other material required by a party to be disclosed to the opposite party before trial by operation of the Rules or by an order of the Court, that the privilege is maintained until the document is used in evidence, save to the extent required for the purposes of the litigation."
I confess that I am uncertain what his Honour meant by that paragraph and whether it is inconsistent with his Honour's immediately preceding views. Counsel before us could offer no compelling resolution of the problem. Perhaps the concluding words of the paragraph mean that in the circumstances of this case there was a waiver.
"In my view, there would be no injustice to the [appellant], if it were not permitted to cross-examine the [respondent] without the [respondent] first having had the opportunity to view surveillance material the [appellant] indicated it wished to tender in evidence or otherwise use at the trial. It is primarily for these reasons I maintained my earlier decision and refused the subsequent application ...."
or supplied and their contents were not "set out" or re-produced as visual images in whole or in part. As Gibbs, C.J. stated in Attorney-General (NT) v. Maurice[18] by reference to authority, it has been held that the privilege in respect of a document is not waived by the mere reference to that document in pleadings or in an affidavit, although the position would be different if the document is reproduced in full in the pleading or affidavit. Dawson, J. said in the same case[19] that for waiver to happen the content of the communication itself must be revealed.[20] Moreover, they were described as "brought into existence for the dominant purpose of litigation", which makes it clear that they were asserted to be privileged from production on the ground of legal professional privilege: compare Esso Australia Resources Ltd. v. Commissioner of Taxation[21]. It may be accepted that by listing them the appellant categorised them as material it then intended to tender or otherwise use at trial. But it had not at that stage used them and it was at liberty to resile from that intention at any time before it actually carried it into effect. I conclude, therefore, that, since what the appellant had done was, in my opinion, not inconsistent with its continued assertion of privilege or - to put the matter concretely - since the surveillance videotapes had not been tendered or otherwise used and their content had not been otherwise revealed, legal professional privilege in them had not been impliedly waived by the appellant. I have found it unnecessary to consider the appellant's argument that there could be no waiver because the listing was done under the compulsion of an order.
"(a) a copy of all medical reports; and (b) affidavits attesting to such other material - existing when the advice is given and of which the employer, Authority or self-insurer or the legal representative of any of them is aware and on which they intend to rely or the substance of which they intend to adduce in evidence in proceedings brought by the worker in accordance with this section or in any related proceedings."
By sub-s.(2DD), in proceedings "in accordance with this section"[26] a medical report or other material is inadmissible in evidence on behalf of the Authority or self-insurer if it was in existence and the employer, Authority or self-insurer, or the legal representative, was aware of it, before the date by which the advice is required to be given and it had not been disclosed to the worker[27]. It is clear from the fact that the originating motion seeking leave to commence proceedings was filed on 23 April 2001 whilst the earliest of the surveillance videotapes listed is described as dated 23 April 2002, as well as from paragraph 3 of the affidavit of Maria Tsikaris sworn 15 October 2002, that the videotapes postdate the date of or for the advice and that accordingly sub-ss.(2DA) and (2DD) do not apply to them. It is therefore unnecessary to consider the meaning of the expression "other material" in the sub-sections.
"In the absence of a specific provision requiring the exclusion of relevant evidence, it is unthinkable that a court should or could exclude relevant evidence as a means of some sort of sanction or punishment for breach of a procedural rule. Whilst there are certain recognised areas in which a judge has a discretion to exclude admissible evidence, especially in criminal jurisdiction, in general he has no right to deprive a party of the right to call relevant admissible evidence."
A similar view was expressed in Douglas v. John Fairfax & Sons Ltd.[38]. Thus, even as to documents which should have been, but were not, discovered, the better view is that, in the absence of a rule to the contrary, they may still be used at trial, subject only to adjournments[39] and costs: Cooke v. Australian National Railways Commission[40] per Olsson, J., citing a reference in Hannan's Local Court Practice to Bohme v. Bohme[41]; though there is in the judgment of the Full Court of the Federal Court in Bourke v. Beneficial Finance Corporation Ltd.[42] an obiter statement that generally the sanction for the failure of a party to discover documents is that the party is unable to tender those documents in evidence. Of course, had the discretion not miscarried on 15 October 2002 there would have been no failure whatsoever to list and, as it was, the failure was a matter of form only, for the respondent did receive the list before trial, albeit late.
"The directions at least indirectly imposed an obligation on [the defendants] to waive that secrecy by otherwise subjecting the conduct of their defence to a restriction unless the trial judge later lifted that restriction. In doing so, the directions derogated from the appellants' legal professional privilege with respect to the engineer's report. The prevailing theory with respect to the proper performance of the judicial function in modern society encourages active case management to reduce issues, avoid surprise and embarrassment, minimise cost and delay, and provide expeditious and efficient justice. However, the adversarial system is not wholly without advantage, and public or private interests will not always necessarily be best served by full disclosure of all evidence, or all evidence in a particular category, prior to trial. More particularly, justice will not necessarily be served by compelling a waiver of all or part of a litigant's legal professional privilege with respect to evidence, or possible evidence, pre-trial. The respondent submitted that legal professional privilege does not exist to confer or preserve tactical advantages at a trial. Irrespective of whether that is an accurate statement with respect to a purpose of the privilege, advantages with respect to the conduct of trial are undoubtedly one of the benefits which routinely result from its existence. The important public interest served by legal professional privilege has been consistently affirmed by the High Court. At least since Baker v. Campbell, generally expressed statutory powers which are literally wide enough to deny or derogate from legal professional privilege have been construed so as to leave the privilege intact. Legislation which would adversely affect legal professional privilege if given its literal effect is read down so as to avoid that result unless the language used clearly reveals an intention to do so. Obviously, a similar approach must be adopted to the construction of subordinate legislation."
McPherson, J.A.[45] stated that the rule evinced no intention to abrogate the claim to legal professional privilege. He went on:
"Rule 101 of the District Court Rules is expressed in terms that are quite general and non-specific, and does so without addressing the matter now being considered or anything resembling it. Even assuming that their purpose, or one aspect of it, is to facilitate active case management, they provide no indication that the power conferred is to be exercisable in derogation of the common law right of a litigant to decide whether or not to relinquish the privilege, or to select the moment at which to do so; in the ordinary course of events, the earliest moment at which that decision is called for is at the trial if and when that party elects to call the evidence and, for that purpose, opens the case which it is proposed to present. On the face of it, r. 101 neither expressly or impliedly interferes with that right or choice."
appellant, would order it to pay the respondent's costs of the appeal, including costs reserved.
[2] There is a question whether "other material" is to be read eiusdem generis with what precedes it or without limitation, as I think the appellant was inclined to accept in the context of the Act and the Practice Note mentioned later. Without deciding the point I have proceeded on the basis of latter interpretation.
[3] The reference to "trial" in this essentially pro forma order, particularly in association with the reference to Rule 34A.35(4)(d) (which is set out below), is clearly in this case a reference to the hearing of the application under s.135A.
[4] A statement by the primary judge at page 2 of his Ruling No.1, referred to later, might on one view, suggest otherwise.
[5] The requirements of para.10 of her Honour's order and Rule 34A.35(4)(d) may be contrasted with the requirement of Rule 34A.31(d) for the court book to contain a copy of each document.
[6] [1998] 4 V.R. 439 at 448-449.
[7] The Court was informed that a later amendment of the Practice Note was irrelevant for present purposes.
[9] At the risk of doing what is proscribed (though with the plea that the proscription is, to adapt Bertrand Russell's concept, language of a higher order than an observation about the merits of a special leave application) reference may be made to observations by Gummow, J. and Hayne, J. in EMCL Pty. Ltd. & Anor. v. Esanda Finance Corporation Ltd. (High Court transcript, 8 September 2000, p.5).
[10] In the notice of appeal called a judgment given.
[11] This seems to invert the onus as to the condition.
[12] (2002) 76 A.L.J.R. 828 at paras.[5]-[7].
[13] Gerlach v. Clifton Bricks Pty. Ltd. at paras.[5]-[7].
[15] In Robbins v. Harbord [1994] SASC 4571; (1994) 62 S.A.S.R. 229 at 236-237 video film was held not to be privileged, but that was the result of the special position of the employer under the South Australian workers compensation legislation.
[16] Attorney-General (NT) v. Maurice [1986] HCA 80; (1986) 161 C.L.R. 475, cited in the second ruling, and especially Mann v. Carnell [1999] HCA 66; (1999) 201 C.L.R. 1 at 13, cited in the first ruling.
[20] The present case is not one where part of a communication or some of certain associated material has been revealed and the question is as to the balance.
[23] [2002] HCA 49; (2002) 192 A.L.R. 561; 77 A.L.J.R. 40 at paras.[9]-[11], [43]-[44], [85]-[87], [132]. See also Baker v. Campbell [1983] HCA 39; (1983) 153 CLR 52; Carter v, Northmore Hale Davey & Leake (1995) 183 CLR 121; and Commissioner of Australian Federal Police v. Propend Finance Pty. Ltd. (1997) 188 CLR 501.
[25] Cases supporting the views stated and their application are cited later.
[26] This expression is found in sub-s.(1)(a)(iii) and (b)(ii), where it refers to proceedings for the recovery of damages at common law, and there is a nice question, on which it is not necessary to express a concluded view, whether in sub-s.(2DD) it extends to an application under sub-s.(4)(b) for leave to bring such proceedings. Unlike sub-s.(2DA), sub-s.(2DD) does not include the words "or in any related proceedings".
[27] Sub-section (2DC) is not presently material as it applies to the worker.
[28] Whether Direction 6 so far as it requires disclosure of privileged surveillance reports and film is valid in the light of the High Court's statements as to the fundamental nature of the privilege (which is available extra curially: Daniels Corporation at paras.[10] and [44]) does not in the circumstances arise and I express no opinion on it.
[29] It is clear, too, from Directions 3 and 5 that "application" means an application for the determination of the degree of impairment under s.135A(2B), as opposed to an application under sub-s.(4)(b) for leave to bring proceedings.
[30] Whether the rule-making power under which those provisions were made is sufficiently clear and specific, within the statements in Daniels Corporation at paras.[11], [43] and [132], to authorise the overriding of the privilege by the provisions by necessary intendment or whether, alternatively or, perhaps, specifically, they or some of them are, in the regard mentioned, valid by reason of s.78(1)(ha) of the County Court Act 1958 (as to which compare Interchase Corporation Ltd. (in liq.) v. Grosvenor Hill (Qld) Pty. Ltd. (No.1) [1999] 1 Qd R 141) are questions which, in the circumstances of this appeal, do not require consideration, and I express no view upon them.
[31] Which may be contrasted with Rule 31(d).
[32] Which does not, however, unlike paragraphs 3 and 4 in combination, contain a sanction for non-compliance.
[34] As exemplified in King v. Nolan [1992] 2 Qd.R.498 at 501, referred to later.
[35] Compare Douglas v. John Fairfax & Sons Ltd. [1983] 3 NSWLR 126 at 134.
[38] At 134, where it was held that there was no power to make an order precluding a defaulting plaintiff from seeking to prove special damages.
[39] Which may include setting aside a part-heard trial and directing a new trial: Southern Cross Exploration NL v. Fire & All Risks Insurance Co. Ltd. (1985) 2 N.S.W.L.R. 340.
[40] (1985) 39 S.A.S.R. 146 at 149.
[41] Unreported, Supreme Court of South Australia (Murray, C.J.), 14 November 1927. I accept the qualification made by Callaway, J.A. in paragraph [2] of his reasons that the statement in the text may not apply in some circumstances.
[42] (1993) 47 F.C.R. 264 at 278; s.l.r. (1994) 181 C.L.R. 678n.
[46] [2000] W.A.S.C.A. 123 at para.[24]. In that case the statement, albeit considered, was clearly obiter.
[51] R.S.C. O.38, r.5 in England and Rule 36.4 in Western Australia.
[53] In Brown v. Metro Meat International Ltd. the section of the workers' compensation legislation requiring the review officer to act fairly in resolving the dispute whether by agreement or otherwise was the focus of the strictly obiter discussion in the principal judgment, that of Wheeler J. Her Honour stated at para.[12] that this was subject to questions of privilege, "which were not raised on this appeal". I observe that sub-s.(1a) inserted in s.96 of the Principal Act, which was referred to in argument before us, did not authorise an order for production of material to other parties.
[54] Counsel for the appellant contended that breach of these paragraphs was not suggested below.
[55] That is, as deriving from a set of pro forma orders the introduction to which referred to the Practice Note of the Chief Judge.
[57] See the discussion earlier of Rule 34A.19.
State of Victoria
Davies [2003] VSCA 65
(1983) 153 CLR 52
(1995) 183 CLR 121
(1997) 188 CLR 501