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[2001] VSCA 138
Court of Appeal (Vic)
2001-08-29
ORMISTON, CALLAWAY and BUCHANAN, JJ.A.
Original judgment source is linked above.
[ 2001] VSCA 138
Limitation of actions - Extension of period within which to sue - Prejudice to respondent - Extent of prejudice to be considered - Cause of action against solicitor responsible for delay a relevant consideration.
against the solicitor, nobody would be interested in testing the extent to which blame should fairly rest on the solicitor, especially as the solicitor is not represented and rarely gives evidence, at least in the more obvious claims. If an unanswerable claim in negligence were held to be ordinarily a bar to a claim for extension, there would be a temptation to down-play the solicitor's role, but, artificially, only so far as necessary as to justify the applicant's delay. The respondent would, equally artificially, be trying to make the negligence claim stronger, but at the risk of making unanswerable the applicant's allegations justifying delay. At least treating negligence as irrelevant would make it possible for the applicant's claim in delay to be tested properly.
to which, having regard to the delay, there is or is likely to be prejudice to the defendant.
"(2) Where an application is made to a court by a person claiming to have a cause of action to which this section applies, the court, subject to sub-section (3) and after hearing such of the persons likely to be affected by that application as it sees fit, may, if it decides that it is just and reasonable so to do, order that the period within which an action on the cause of action may be brought be extended for such period as it determines. (3) In exercising the powers conferred on it by sub-section (2) a court shall have regard to all the circumstances of the case including (without derogating from the generality of the foregoing) the following - (a) the length of and reasons for the delay on the part of the plaintiff; (b) the extent to which, having regard to the delay, there is or is likely to be prejudice to the defendant; (c) the extent, if any, to which the defendant had taken steps to make available to the plaintiff means of ascertaining facts which were or might be relevant to the cause of action of the plaintiff against the defendant; (d) the duration of any disability of the plaintiff arising on or after the date of the accrual of the cause of action; (e) the extent to which the plaintiff acted promptly and reasonably once he knew that the act or omission of the defendant, to which the injury of the plaintiff was attributable, might be capable at that time of giving rise to an action for damages; (f) the steps, if any, taken by the plaintiff to obtain medical, legal or other expert advice and the nature of any such advice he may have received."
"Whilst I accept that by reason of the lapse of time there would be prejudice to the [appellant] and to [the insurer] in defending any proceeding brought by the [respondent], I do not consider that any of the specific matters raised as indicia of actual prejudice is, of itself, established, or to the extent to which it does arise, to be of sufficient severity to preclude a fair trial of the issues between the parties."
His Honour's reference to failure to establish specific items of prejudice is explained by his use of the following passage from the judgment of Toohey and Gummow, JJ. in Brisbane South Regional Health Authority v. Taylor[5], where their Honours said:
"There is an evidentiary onus on the prospective defendant to raise any consideration telling against the exercise of the discretion. But the ultimate onus of satisfying the court that time should be extended remains on the applicant. Where prejudice is alleged by reason of the effluxion of time, the position is as stated by Gowans, J. in Cowie v. State Electricity Commission (Vict) [1964] VicRp 103; [1964] V.R. 788 at 793 in a passage which was endorsed by Gibbs, J. in Campbell v. United Transport Pty. Ltd. [1996] Qd R. 465 at 474: `It is for the respondent to place in evidence sufficient facts to lead the court to the view that prejudice would be occasioned and it is then for the applicant to show that these facts do not amount to material prejudice.'"
not consistent with that requirement to rule out potential prejudice altogether because the fact that it has occurred or will necessarily occur has not been proven.
"While it might be said that on the evidence before the court the rights against the legal representatives appear to be strong, there is no admission of negligence by the legal representatives and the issues that may arise in any such action have not been investigated or pursued fully in these proceedings. In any event, confining Mr Scardamaglia to an action against the legal representatives would carry with it its own prejudices. He would be able to seek compensation not in respect of his injuries, but for his loss of his right to sue Repco. He would find himself having to prove two cases - the original case against Repco and the further case, the case against the legal representatives. The proceeding would, therefore, be more time consuming and more costly. There would also be a real risk, that, if successful, any sum recovered would be less than any sum that he would have recovered in the original proceeding; for any damages awarded would be for the lost chance to recover damages in the proceedings against Repco."
"I consider that on the evidence before the Court in this Application, most, if not all of the unknown facts identified and discussed by Smith, J. are in existence. I do not regard it as appropriate to pay attention to the possibility of a right of action against the former solicitor in this Application."
"The question posed by s23A is whether, having regard to all the circumstances of the case, including the circumstances mentioned in paras (a) to (f) of subs(3), it is just and reasonable to extend the period. This requires consideration of the conduct and position of both parties, including the effect of the outcome of the application on each of them. ... It is for the plaintiff to satisfy the Court that it is just and reasonable to extend the period."
availability of a cause of action against the solicitor of the respondent, to extend the period within which proceedings may be brought by the respondent.
[1] Though in the present case difficulties arising from the concept of "loss of a chance" would be minimal, at least so it would seem.
[2] Brisbane South Regional Health Authority v. Taylor [1996] HCA 25; (1996) 186 C.L.R. 541.
[3] See Holt v. Wynter [2000] NSWCA 143; (2000) 49 N.S.W.L.R. 128 and compare, because the legislation was similar to s.23A, Sydney City Council v. Zegarac (1998) 43 N.S.W.L.R. 195.
[4] Cf. Anisiena v. H. Crane Haulage Pty. Ltd. [1974] VicRp 81; [1974] V.R. 670 at 674 per Starke, J.; Koumorou v. State of Victoria [1991] VicRp 66; [1991] 2 V.R. 265 at 273 per Brooking, J.; Smith v. Healthcope Pty. Ltd., unreported, 30 June 1994, Eames, J.
[5] [1996] HCA 25; (1997) 186 C.L.R. 541 at 547.
[6] The provision the subject matter of Brisbane South also was in a form that was different to that of s.23A. See below.
[7] See Boughey v. R. [1986] HCA 29; (1986) 161 C.L.R. 10 at 20-21 per Mason, Wilson and Deane, JJ.
[8] [1996] VicRp 2; [1996] 1 V.R. 7 at 15.
[9] See, for example, Birkett v. James [1978] A.C. 297 at 324 per Lord Diplock and at 366 per Lord Edmund Davies; Soper v. Matsukawa [1982] VicRp 96; [1982] V.R. 948 at 951 per Young, C.J.; Tavsanli v. Philip Morris (Australia) Ltd., unreported, Young, C.J., 18 September 1989, at 11.
[10] Birkett v. James, above, at 330 per Lord Salmon; Cory v. Simpson [1983] 3 All E.R. 369 at 374 per Stephenson, L.J.; Firman v. Ellis [1978] Q.B. 886 at 909 per Lord Denning, M.R., at 912 per Ormrod, L.J. and at 916 per Geoffrey Lane, L.J.; McKenna v. McKenna [1984] VicRp 58; [1984] V.R. 665 at 680 per McGarvie, J.; Noja v. Civil & Civic Pty Ltd [1990] FCA 135; (1990) 26 F.C.R. 95. In Thompson v. Brown Construction (Ebbw Vale) Ltd [1981] 2 All.E.R. 296 at 303 Lord Diplock said that in exercising a discretion to extend a limitation period the fact that a claimant had "a claim over against his solicitor ... must be a highly relevant consideration." (In Birkett v. James the House of Lords was dealing with an application to dismiss an action for want of prosecution.)
[11] Johnson v. Perez [1988] HCA 64; (1988) 166 C.L.R. 351.
[12] Cf. Lord v. Australian Safeway Stores Pty. Ltd. [1995] VICSC 212; [1996] 1 V.R. 614 at 622 per Phillips, J.A.; Sydney City Council v. Zegerac (1998) 43 N.S.W.L.R. 195 at 201 per Mason, P.
[14] Holt v. Wynter [2000] NSWCA 143; (2000) 49 N.S.W.L.R. 128 at 147 per Sheller, J.A., with whom Meagher, J.A., Handley, J.A. and Brownie, A-J.A. agreed.
[15] See the legislative history described by Priestley, J.A. in Sydney City Council v. Zegerac, above, at 202-222
[16] Brisbane South Regional Health Authority v. Taylor, above, at 551 per McHugh, J.
[17] Brisbane South Regional Health Authority v. Taylor, above, at 549-50 per Toohey and Gummow, JJ.
[18] [1988] VicRp 16; [1988] V.R. 123 at 125-6.
Tsiadis
Patterson [2001] VSCA 138