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[1999] VSC 415
Supreme Court of Victoria
1999-10-28
HEDIGAN, J.
Original judgment source is linked above.
Easements - Lost modern grant - Principles - Flats constructed in 1971-2 - Nearby residents using block as cut-through - Flats sold, new owner blocking walkway - Whether claimants had acquired rights by way of easement to use walkway. Knowledge of owner of servient tenement - Actual or constructive knowledge - Whether owner put on inquiry. Servient tenement leased at time of commencement of user - Whether fact that owner of servient tenement not in possession or occupation at time of commencement of user by each claimant defeats claimed easement.
We act as managing agents for the above block of flats and have been requested by the owners Rosuma Pty. Ltd. to reply to your letter of 10th December 1974 pertaining to car parking at the property.
We set out hereunder details relating to this matter.
Soon after the building was occupied we received complaints from the tenants that the driveway on the southern boundary was being used by residents in Woodside Crescent and by vehicular traffic from Williams Road as a 'shortcut' to Mathoura Road. Cars were using this thoroughfare at all hours of the day and night and travelling at excessive speeds, causing annoyance to residents as well as creating a potential danger to them from the speeding cars.
As there was already adequate car parking on site, and spaces allocated on the southern boundary but not being used, it was decided to beautify the property by landscaping the driveway, thus achieving the following:-
(a) the elimination of the 'speedway' between Woodside Crescent and Mathoura Road;
(b) reducing the noise and danger factor to residents;
(c) beautifying the property by introducing additional gardens.
We trust that the above is satisfactory to you, but should you require any additional information, please do not hesitate to contact our Malvern office."
The letter was apparently signed by Mr. Pitard. On this basis, what Mr. Kanis said was not correct. There was a driveway from Woodside Crescent through the property to Mathoura Road but Kanis said that from the time the apartment block was constructed the garden bed prevented cars from driving through the property from Woodside Crescent to Mathoura Road. I note that Kanis also said that before the apartment block was finished, he engaged Mr. Pitard of Trebilcock Bros. as managing agent. Mr. Kanis, who lived elsewhere, occasionally inspected it. He said that he did not know at any time when he owned the property that any residents of Woodside Crescent or any other person who was not a tenant was using any part of the property for access between Woodside Crescent and Mathoura Road.
(1) the doing of an act by a person or persons upon the land of another;
(2) the absence of right to do that act in the person doing it;
(3) the knowledge of the person affected by it that the act is done;
(4) the power of the person affected by the act to prevent it, either by an act on his own part or by action in the courts;
(5) the abstinence by that person from interference of such a length of time which renders it reasonable for the Court to say that it shall not afterwards interfere to stop the act being done.
"Dear Sir, Re 91 Mathoura Road It has been brought to my attention that a condition on permit No.70/254 issued in respect of the above flats is not being adhered to. Condition 3 on the permit reads: 'Parking for a minimum of 14 vehicles shall be provided for the 11 flats proposed'. It has been noticed that only 11 spaces are provided on the site. I should be pleased if you could make arrangements to rectify the situation and inform this office when the work is done."
The response to that letter has already been reproduced by me in these reasons and it is a letter from Trebilcock Bros Purdy Pty. Ltd., the managing agents for the block of flats and apparently written by Mr. M.S. Pitard.
"The law imputes to the principal and charges him with all notice or knowledge relating to the subject matter of the agency which his agent acquires or obtains while acting as such agent."
This passage is adopted from Mechem Law of Agency (2nd ed.) s.183, a U.S. publication. However, the comment on Article 97 in Bowstead is more cautious about its application, citing from Palles, C.B. in Taylor v. Yorkshire Insurance (1913) 2 Ir.R. 121 "when a question of notice, or knowledge, arises, we find ourselves overwhelmed in a sea of authorities, not altogether reconcilable with each other". If, as I accept to be the proper legal conclusion, that information "constructively" acquired cannot be imputed to the principal, then reliance by the claimants on the alleged observations by gardeners, or painting and maintenance men, does not advance the claimant's case at all. There was some evidence from the Byrnes, Maryanne Wulff, Leon Haskin, Mr. Grouse and Ms Bishop about observing, and being observed by, some workmen who were apparently engaged by the estate agent on behalf of Rosuma, which paid for the work by having its cost deducted prior to the remission of rentals. There was also some debate as to whether or not such men were employees or independent contractors. Mr. Holder said the expectation was that such men would report anything unusual although the evidence falls well short of there being any legal obligation on them to do it. In addition, any evidence of any knowledge by a gardener or maintenance person or similar person, or by reason of complaints about rubbish on the property, will not be of any benefit to the claimants if the knowledge was acquired after 1979. Mrs. Byrne gave evidence of a gardener and a maintenance person seeing her use the pathway but this was "more in later years because the tenants became more messy" or a period about five or six years ago. I do not regard Mrs. Byrne's complaints, well justified as they may have been, as necessarily indicating to anyone that she was asserting any kind of right. She did not recall ever meeting an agent on the property and did not identify the time when she complained about rubbish to agents. One such complaint was about rubbish in 91 Mathoura against her back fence.
"Are the facts such as to enable the court to say that the appellant not only might have acquired, but ought to have acquired, a knowledge of the agreement and that he would have acquired that knowledge but for his negligent conduct of his own business. The onus is upon the respondent of establishing the affirmative of that issue. It is for him to put forward facts upon which the court may reasonably find in his favour. If, on the facts proved, that finding cannot be reasonably inferred, or if he has left the matter doubtful, he must fail."
"The user must be by or on behalf of a fee simple owner against a fee simple owner. The whole theory of prescription at common law is against presuming any grant or covenant not to interrupt, by or with anyone except an owner in fee ... An easement or profit for life or for years for example, may be expressly granted but cannot be acquired by prescription, for the theory of prescription presumes that a permanent right has been duly created at some unspecified time in the past. A claim by prescription must therefore fail if use can be proved only during a time when the servient land was occupied by a tenant for life or for years, for then the fee simple owner may never have been in a position to contest the user."
This passage appears to express the opinion that a claim for easement by user fails if it is only proved during a period of occupancy by tenants, the owner of the fee simple not being in occupation. Megarry and Wade cites the decision of the Court of Appeal in Pugh v. Savage (supra). The judge at first instance in that case had held that the existence of a tenancy at any stage during the alleged period of use was necessarily fatal to the claim for an easement arising by prescription, relying upon an earlier statement in the law in the second edition of Megarry and Wade which was altered by the addition of the final sentence in the paragraph her cited. The Court of Appeal (principal judgment by Cross, L.J.) disapproved of the width of that proposition. In that case, the tenancy had not come into existence until after the commencement of the period of user. Cross, L.J. held that such a tenancy was not necessarily fatal to a claim for an easement rising by prescription and distinguished such a situation from the case in which a dominant tenant was let at the commencement of the period of user stating:
"That a distinction can properly be drawn between cases where the tenancy was in existence at the beginning of the period of user and cases where the tenancy came into existence in the course of the period of user, is surely only common sense. If a tenancy is in existence at the beginning of a period of user it may well be unreasonable to imply a lost grant by the owner at the beginning of the user. He might not have been able to stop the user, even if he knew about it. If, on the other hand, you get a period of user against an owner or owners without any evidence that they did not know about it when they were in possession, then afterwards the grant of a tenancy, though undoubtedly such a tenancy during the period of user is a matter to be considered, it would be quite wrong to hold that it is a fatal objection to presuming a grant ...".
Harman, L.J. (386) agreed with the statement of principle that a period of user cannot begin to run by prescription if at the time the servient tenement owner was not in possession because in such circumstances a servient owner would not of necessity have any knowledge of user or any power to prevent it, because he was out of possession. Thus both knowledge and power to prevent are features of the modern cases. In Piromalli v. Di Masi (supra), a case in which an easement of way was claimed, the previous owner of the servient tenement had been out of possession for many years, the lot having been leased as a service station. There was evidence that horses used to be taken across it to stables on the dominant tenement and that the customers of a betting shop on the dominant tenement used to pass across the servient tenement. The Full Court of the Supreme Court of Western Australia applied the principles pronounced by Fry, J. in Dalton v. Angus (supra) and held that it was necessary to show that the owner knew of the adverse user and was a in a position to prevent it physically or by action and had abstained from doing so. In Piromalli, the statements of Cross, L.J. in Pugh v. Savage were followed. During the relevant 21 year period the servient tenement had been held by a tenant pursuant to the lease and its extensions. The owner of the tenement, had no power to prevent the betting shop entrepreneur from using the land as a way to the rear of his premises. Burt, C.J. cited from Baxter v. Taylor [1832] EngR 780; (1832) 4 B. & Ad. 72 at 75:
"He could not maintain an action of trespass in his own name, because he was not in possession of the land nor an action on the case for injury to the reversion, because in point of fact there was no such permanent injury as would be necessarily prejudicial to it; as, therefore, he had no remedy by law for the wrongful acts done by the defendant. The acts done by him or any other stranger would be no evidence of right against the plaintiff so long as the land was in the possession of a lessee."
His Honour also cited Davies v. Du Paver and went on to say (176):
"And if it be permissible in a case based upon the Prescription Act to go beyond the period of 20 years preceding the issue of the writ and to a point of time prior to the lease to Caltex to show the origin of the user so as to create a base for a submission that time continue to run during the term of the lease it would, in my opinion, be necessary to show a user as of right against the fee simple owner as at the time when the tenant of the servient tenement entered into possession and knowledge actual or imputed in the servient owner at that time of the acts done which constituted the user. If it be right to say that time can run against the owner of the servient tenement while he is out of possession and while the land is let to a tenant then it must, in my opinion, be shown that the owner of the servient tenement knew of the user and ought to have known of the user when he was still in possession and in a position to stop it. The user as of right and with knowledge in fact or imputed must begin when the owner of the fee simple of the servient tenement is still in possession. Time would not, I think, run under the statute in the face of a finding that the owner of the servient tenement had no such knowledge of the user when he went out of possession. That conclusion seems to me to be consistent with the judgment of Cross LJ in Pugh v. Savage ... and one cannot, in my opinion, formulate the law in a way more favourable to the respondents to this appeal."
"If they are to be viewed in that way, then Davies v. Du Paver and Pugh v. Savage support the proposition. Davies v. Du Paver is also authority that the question of knowledge in the servient owner is a matter of fact for the judge.... In my view Mr. Edgley as the legal and beneficial owner of the laneway had possession of the land in the sense that he alone was entitled to possession, was in the same position as any other owner in possession of his land and was under a duty to act diligently in the protection of his interests."
Thus, the decision confirmed, if it were necessary, that if the owner of the servient tenement alone is entitled to possession, he is under a duty to act diligently in protection of his interests. It would appear from that decision that time would not have run against the servient owner if he had not been in occupation of the land at the relevant time.
"Where rights are acquired by prescription they must be acquired against the fee simple owner of the servient tenement, not against the holder of a limited interest in that land, for example, a lessee."
"... where an easement is claimed by prescription it must be claimed in favour of the fee simple of the dominant tenement as against the fee simple of the servient tenement; however it is sufficient to show that the user began against the fee simple owner even though the servient tenement was subsequently settled or let. Consequently, no easement can be claimed by prescription for estate or interest less than a perpetual one... an easement for an estate less than an absolute interest may, however, be created by express grant or may arise otherwise by operation of law."
These pronouncements of principle were suggested by counsel for the claimants not to represent the modern law, he relying on an article by V. Delaney "Lessees and the Doctrine of Lost Grant" 1958 74 L.Q.R. 1983. That article examined a number of cases and earlier texts relating to the Prescription Act 1832 (which does not apply in Victoria) and concluded that the cases had misunderstood the statute, the thesis being that an easement under the doctrine of lost modern grant could be granted by a tenant of the servient tenement. The cases, relied upon and referred to by Mr. Cawthorn, are primarily Irish authorities which appear to run counter to the tenor of authority in England and Australia. The article, in any event, was published prior to the decisions in Pugh v. Savage, Piromalli v. Di Masi, Hamilton v. Joyce and Gangemi v. Watson. It was also published before those editions of Megarry and Wade and Halsbury to which I have referred. Counsel for the developer argued that in the real sense of the words "occupation and possession" neither Mr and Mrs Kanis or Rosuma were ever in occupation or possession of either the units or the external common property at the time of the commencement of each period of alleged user, by which I mean the period of alleged user, of each of the claimants. This appears to be correct. The argument was put that this was so even if the relationship between the owner and the tenants of the external common property was a lease, a licence or an easement. If it was a lease, then the authorities indicate that the existence of the tenancy at the commencement of each period of user negatives presumption of the grant of an easement. If the relationship was one of licence or easement the servient owner was still not in possession or occupation of the common property (and the retention of a right to enter for limited purposes does not alter the situation). Some modern authorities appear to have given as much emphasis to "not being in occupation" as an independent and separate ground. Counsel for the developer argued that this was the modern law, irrespective of the knowledge, actual or constructive, of user by the servient owner or the power in the servient owner to prevent the user. I do not find it necessary to consider the extent to which that represents the present state of the law because, as would already appear, I do not make a finding of knowledge of user in the servient owner.
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