Did the Tribunal err in applying Aust-Homes Investments?
- At [42] of the reasons for decision the Tribunal Member correctly set out the principle enunciated in Aust Home Investments upon which an award of costs should be made in circumstances where there has been no hearing on the merits. The Tribunal Member correctly identified at [42] and [43] that a finding was required not only in relation to whether the owner acted reasonably in commencing the proceedings but also in relation to whether the builder acted unreasonably in defending the proceedings. The Tribunal Member referred at [43] to the owner's submission that the builder acted unreasonably in defending the matter.
- However, in determining the matter with respect to the test in Aust Home Investments the Tribunal at [64] dealt only with whether the owner had been reasonable in commencing and maintaining the proceedings. At [66] the Tribunal Member referred to the negotiations between the parties and stated that it assumed "that the representatives have used their best endeavours to secure an early agreement to the dispute". The finding at [66] cannot amount to a finding that the builder acted unreasonably so as to support a finding of costs against it. Ultimately at [68] the Tribunal held that it was reasonable and necessary for the owner to maintain her claim. At [69] the Tribunal Member based his decision to make an order for costs in favour of the homeowner solely on a finding that she was the successful party in the proceedings.
- Nowhere in the reasons for decision does the Tribunal Member deal with the second limb of the test in Aust Homes Investments; that is, whether the builder acted unreasonably in defending the proceedings.
- Under clause 20 of the CTTT Regulation the Tribunal had a wide discretion in making a costs order. The principles to be applied in considering whether a discretion has miscarried are set out in House v. The King (1936) 55 CLR 499, at pp 504-505:
It is not enough that the judges composing the appellate court consider that, if they had been in the position of the primary judge, they would have taken a different course. It must appear that some error has been made in exercising the discretion. If the judge acts upon a wrong principle, if he allows extraneous or irrelevant matters to guide or affect him, if he mistakes the facts, if he does not take into account some material consideration, then his determination should be reviewed and the appellate court may exercise its own discretion in substitution for his if it has the materials for doing so. It may not appear how the primary judge has reached the result embodied in his order, but, if upon the facts it is unreasonable or plainly unjust, the appellate court may infer that in some way there has been a failure properly to exercise the discretion which the law reposes in the court of first instance. In such a case, although the nature of the error may not be discoverable, the exercise of the discretion is reviewed on the ground that a substantial wrong has in fact occurred.
- The Appeal Panel is satisfied that in not making a finding in relation to the second limb of the Aust Homes Investments test which he had set out in his decision as the guiding principle to be applied, the Tribunal Member fell into legal error in the application of the correct legal test as identified by him.
- As we have found a question of law arises in regard to this issue, we consider it unnecessary to determine the remaining grounds of appeal.