Library Bulletin

High Court of Australia

Income tax

Commissioner of Taxation v Bendel [2026] HCA 18 (Opens in a new tab/window)

Gageler CJ, Gordon, Edelman, Steward, Gleeson, Jagot and Beech-Jones JJ
10 June 2026
Catchwords

INCOME TAX (Cth) - Assessable income - Distributions to entities connected with private company - Loans treated as dividends under s 109D of Income Tax Assessment Act 1936 (Cth) ("ITAA 1936") - Where deed of settlement of discretionary trust required amounts set aside for any beneficiary to be held on separate trust - Where trustee made resolutions to set aside amounts of net income for corporate beneficiary - Where corporate beneficiary had unpaid present entitlements - Whether resolutions to set aside amounts effected distributions - Whether amounts set aside sufficiently certain for creation of separate trusts - Whether relationship of debtor and creditor arose between trustee and corporate beneficiary - Whether unpaid present entitlements were loans for purposes of s 109D(3) of ITAA 1936.

Tort

Abdel-Hady v Commonwealth of Australia [2026] HCA 17 (Opens in a new tab/window)

Gageler CJ, Gordon, Edelman, Steward, Gleeson, Jagot and Beech-Jones JJ
10 June 2026
Catchwords

TORT - False imprisonment - Defences - Where plaintiff detained under s 189(1) of the Migration Act 1958 (Cth) following visa cancellation - Where since 28 July 2022 there was no real prospect of plaintiff's removal from Australia becoming practicable in reasonably foreseeable future - Where in November 2023 NZYQ v Minister for Immigration, Citizenship and Multicultural Affairs (2023) 280 CLR 137 reopened and overruled Al- Kateb v Godwin (2004) 219 CLR 562 - Where effect of NZYQ was that ss 189(1) and 196(1) of the *Migration Act *did not authorise plaintiff's detention from 28 July 2022 - Where Commonwealth accepted elements of tort of false imprisonment established - Where Commonwealth accepted it was vicariously liable for liability of detaining officer - Where Commonwealth propounded novel common law defence to negative liability from 28 July 2022 to time of orders in NZYQ on 8 November 2023 - Whether Commonwealth's defence should be recognised to negative common law liability of detaining officer for tort of false imprisonment.

Victorian Court of Appeal

Contract

Selak v National Tiles Co Pty Ltd [2026] VSCA 118 (Opens in a new tab/window)

McLeish and Lyons JJA and Nichols AJA
29 May 2026
Catchwords

CONTRACT - Implied terms of cooperation - Implied obligation not to hinder or prevent the fulfilment of the purpose of express promise in agreement - Implied obligation to cooperate to allow contracting parties to have benefit of agreement - Contract for option to acquire shares and provision of draft shareholders' agreement - Whether judge erred in finding no breach of cooperation terms because shareholders' agreement inconsistent with express promise in contract subject to negotiation - Shareholders' agreement in final form when provided - No subsequent conduct evincing intention to comply with express promises in contract - Breach of cooperation terms established.

Contracts

Rowson v Alpass [2026] VSCA 120 (Opens in a new tab/window)

McLeish and Orr JJA and Nichols AJA
04 June 2026
Catchwords

CONTRACTS - Formation - Oral contracts - Contract to purchase legal practice of which respondent was appointed receiver, alleged to have been formed in discussion between parties - Whether associate judge erred in finding no agreement formed.

Landlord and tenant

McDiarmid v Homes Victoria [2026] VSCA 126 (Opens in a new tab/window)

Beach JA
05 June 2026
Catchwords

LANDLORD AND TENANT - Application for leave to appeal - Rental agreement terminated - Goods left on property after termination - Owner (landlord) refusing to store goods for more than 14 days - Application to VCAT by administrator of estate of former tenant for order requiring owner to store goods for more than 14 days - VCAT order extending storage period by 21 days - Applicant dissatisfied with VCAT order - Application for leave to appeal to Trial Division from VCAT order refused by primary judge - Proposed appeal to Court of Appeal having no prospects of success - Application for leave to appeal totally without merit - Application for leave to appeal refused.

Corporations

Lao v Taing [2026] VSCA 131 (Opens in a new tab/window)

Walker and Whelan JJA and Delany AJA
09 June 2026
Catchwords

CORPORATIONS - Oppression - Application for leave to appeal - Company undertook land acquisition and sale as trustee for family interests of Taing family (40%) and Lao family (60%) - Payments made from proceeds of sale to which recipients not entitled - Applicant, a member of Lao family, found responsible for payments from proceeds of sale - Payments found contrary to interests of the Company - Applicant held to have been responsible for ensuring payments checked and ensuring properly incurred - Whether trial judge mischaracterised applicant's role.

Taxation

Commissioner of State Revenue v Vicinity Funds RE Ltd [2026] VSCA 119 (Opens in a new tab/window)

Beach and Kennedy and Walker JJA
02 June 2026
Catchwords

TAXATION - Duties on transfers of land - Land valuation - Transfers of two fee simple estates following exercise of call options at price of $1 each - Properties subject to existing 299-year leases - Where tenants installed substantial fixtures on leased premises - Assessment of unencumbered value of land under s 22 of Duties Act 2000 ('Duties Act') - Where leases 'disregarded' as Commissioner not satisfied that no collateral purpose to reduce duty - Where Commissioner considered s 22A not engaged or otherwise 'subject to' s 22(2) by reason of disregarding leases - Disregarding lease does not extend to disregarding tenant's property rights under s 154A of Property Law Act 1958 ('PLA') - Section 22A is engaged in relation to value of tenant's fixtures - Commissioner failed to consider state of satisfaction under s 22A(2) of Duties Act - Application for leave to appeal granted - Appeal dismissed - Valuer-General v AWF Prop Co 2 Pty Ltd (2021) 65 VR 327; Chief Commissioner of State Revenue v Centro (CPL) Ltd (2011) 81 NSWLR 462; Commissioner of State Revenue v Pioneer Concrete (Vic) Pty Ltd (2002) 209 CLR 651; Trust Co Ltd v Chief Commissioner of State Revenue (NSW) (2007) 70 ATR 505, considered.

Criminal law

Ahmed v The King [2026] VSCA 117 (Opens in a new tab/window)

McLeish and Boyce and T Forrest JJA
29 May 2026
Catchwords

CRIMINAL LAW - Appeal - Sentence - Culpable driving causing death - Refuse preliminary breath test - Whether individual sentences, orders for cumulation, total effective sentence and non-parole period manifestly excessive - Driving under influence of alcohol and methylamphetamine - Driving at excessive speeds across multiple lanes of traffic - Collision with another vehicle - Failure to stop - Driving through multiple red lights - Collision with another vehicle - Passenger in other vehicle killed - Sentence of 13 years highest in Victoria for culpable driving causing death - Standard sentence scheme - Current sentencing practices - General deterrence - Leave to appeal granted - Appeal dismissed.

Ahmed v The King [2026] VSCA 133 (Opens in a new tab/window)

Taylor and Orr and Kidd JJA
10 June 2026
Catchwords

CRIMINAL LAW - Appeal - Application for leave to appeal against conviction - Applicant convicted of trafficking and possessing drugs of dependence - Applicant's DNA found on clip seal region of bags containing drugs - Crime scene compromised by police - Possibility of secondary transfer of applicant's DNA could not be eliminated - Whether DNA evidence correctly admitted - Application for leave to appeal refused.

Austin v DPP [2026] VSCA 127 (Opens in a new tab/window)

Walker and Whelan JJA
09 June 2026
Catchwords

CRIMINAL LAW - Sentence - Application for extension of time and leave to appeal - Aggravated recklessly exposing emergency worker to risk by driving - Sentence of 21 months' imprisonment - Whether manifestly excessive - Gravity of offending not high - Unusually powerful factors in mitigation - Both Verdins and Bugmy principles apply - Prisoner's experience of custody 'far worse' than for prisoners in general - Application for extension of time granted - Leave to appeal granted - Appeal allowed - Resentenced to 13 months' imprisonment on charge 3 - Resulting total effective sentence of 2 years' imprisonment - Inappropriate to fix non-parole period.

Bednar v The King [2026] VSCA 114 (Opens in a new tab/window)

Beach and Boyce and Kaye JJA
29 May 2026
Catchwords

CRIMINAL LAW - Conviction - Appeal - Application for leave to bring second appeal - Applicant convicted of murdering his mother - New evidence alleged to support hypothesis that prosecution witness murdered deceased and engaged in elaborate scheme to frame applicant - Requirement for new evidence to be fresh and compelling - New evidence not fresh and compelling - Applicant's hypotheses about prosecution witness fanciful - Application for leave to appeal refused.

Benson (a pseudonym) v The King [2026] VSCA 137 (Opens in a new tab/window)

Beach and Kennedy and Kaye JJA
11 June 2026
Catchwords

CRIMINAL LAW - Evidence obtained illegally and/or improperly - Judge refused to exclude evidence under s 138(1) of the Evidence Act 2008 - Applications for leave to appeal interlocutory decision - Applicant (Benson) suffered injury and resulting memory loss after falling off electric scooter - Police conducted unauthorised search of applicant's (Benson's) phone to determine whether he was the victim of a crime - Photographs relevant to possible offending on phone - Whether evidence obtained illegally and/or improperly - Whether desirability of admitting evidence outweighs undesirability of admitting evidence obtained as a result of unauthorised search - Probative value of evidence high - Gravity of illegality and/or impropriety low - Judge correctly refused to exclude evidence - Applications for leave to appeal refused.

Bullock v The King [2025] VSCA 122 (Opens in a new tab/window)

Kidd JA
04 June 2026
Catchwords

CRIMINAL LAW - Sentence - Application for leave to appeal - Causing injury recklessly (1 charge) - Common law assault (1 charge) - Make threat to destroy property (1 charge) - Make threat to kill (1 charge) - Family violence context to offending - Pleaded guilty to damaging property (1 charge) - Sentence imposed following a trial - TES 7 years and 3 months imprisonment NPP of 3 years and 9 months - Whether sentence and cumulation manifestly excessive - Application for leave to appeal refused.

DPP v Joannidis [2026] VSCA 134 (Opens in a new tab/window)

McLeish and Boyce and T Forrest JJA
10 June 2026
Catchwords

CRIMINAL LAW - Appeal - Sentence - Crown appeal - Five charges of dangerous driving causing death - Total effective sentence of 5 years and 6 months' imprisonment - Non-parole period of 3 years - Whether individual sentences, orders for cumulation and total effective sentence manifestly inadequate - Inherently dangerous intersection - Warning signs prior to intersection - Respondent not alcohol or drug-affected at time of offence - Not speeding - Dangerously inattentive for at least 375 metres - No prior convictions - Early guilty pleas - Serious mental illness - Verdins limbs 3, 5 and 6 found below and not challenged - Individual sentences and cumulation within range - Appeal dismissed.

DPP v Low [2026] VSCA 136 (Opens in a new tab/window)

Taylor and Boyce and T Forrest JJA
10 June 2026
Catchwords

CRIMINAL LAW - Sentence - Appeal against inadequacy of sentence - Negligently causing serious injury - Driving motor vehicle - Respondent drove whilst intoxicated - Respondent drove through red lights causing collision - Other driver suffered serious injuries - High level of negligence - Sentence of 12 months' imprisonment and 2-year community correction order imposed - Whether sentence manifestly inadequate - Appeal allowed - Respondent resentenced.

DPP v Wu [2026] VSCA 132 (Opens in a new tab/window)

Taylor and Boyce and T Forrest JJA
10 June 2026
Catchwords

CRIMINAL LAW - Sentence - Appeal by Director of Public Prosecutions - Charges of rape, sexual assault and producing child pornography - Respondent offended against unconscious housemate during six episodes over two years - Respondent filmed offending and retained recordings - Respondent to be sentenced as a serious sexual offender for five charges - Final charge of rape attracted standard sentence provisions - Total effective sentence of 3 years and 6 months' imprisonment - Non-parole period of 2 years - Whether sentences and non-parole period manifestly inadequate - Whether residual discretion should be exercised - Appeal allowed - Respondent resentenced - Delay a significant factor in resentencing exercise.

Kuru v The King [2026] VSCA 125 (Opens in a new tab/window)

Beach and Kennedy and Kaye JJA
05 June 2026
Catchwords

CRIMINAL LAW - Conviction - Application for extension of time within which to seek leave to appeal against conviction - Intentionally causing serious injury in circumstances of gross violence - Whether not accommodating applicant's acquired brain injury caused trial to miscarry - Whether opinion evidence led from informant caused trial to miscarry - Whether body-worn camera footage wrongly admitted into evidence - Proposed grounds of appeal not reasonably arguable - Application for extension of time refused.

Malwal v The King [2026] VSCA 135 (Opens in a new tab/window)

Taylor and Boyce and T Forrest JJA
10 June 2026
Catchwords

CRIMINAL LAW - Appeal - Conviction - Aggravated home invasion and causing injury intentionally - Trial run on narrow basis - Dispute as to whether applicant entered home and participated in aggravated home invasion - Co-accused - Reliability and credibility of witness - Primary witness described three then four offenders in house - Whether verdict unreasonable or cannot be supported having regard to evidence - Witness explanation plausible - Triple zero call by other witness described four offenders in house - Primary witness' evidence credible and reliable - Strong circumstantial evidence linking applicant with offending - Ample evidence to find applicant guilty - Leave to appeal refused.

Sadiq v The King [2026] VSCA 128 (Opens in a new tab/window)

Walker and Whelan JJA
09 June 2026
Catchwords

CRIMINAL LAW - Sentence - Application for extension of time in which to file application for leave to appeal - Applicant pleaded guilty to attempted possession of commercial quantity of unlawfully imported border-controlled drug (methamphetamine) - Sentenced to 5 years' imprisonment with two years, six months' non-parole - Sentencing judge not informed that applicant not Australian citizen and would have his visa cancelled as consequence of sentence - Applicant submitted sentencing discretion miscarried - Applicant sought to rely on further evidence of his migration status - No reasonable prospect that a different sentence would be imposed - Application for extension of time refused.

Shephard (a pseudonym) v The King [2026] VSCA 123 (Opens in a new tab/window)

Kidd JA
04 June 2026
Catchwords

CRIMINAL LAW - Sentence - Application for leave to appeal - Sexual penetration of a child under 12 - Sexual penetration of a child under 16 - Sexual assault of a child - Sexual activity in the presence of a child - Sentence imposed following a trial - TES 12 years and 6 months imprisonment NPP 8 years and 6 months - Lifelong reporting conditions on the sex offenders' registry - Whether court erred in considering aggravating features of the offending - Whether sentence and cumulation manifestly excessive - Application for leave to appeal refused.

Singh v The King [2026] VSCA 121 (Opens in a new tab/window)

Taylor and Osborn JJA
04 June 2026
Catchwords

CRIMINAL LAW - Sentence - Application for leave to appeal against sentence - Applicant convicted of attempted aggravated carjacking, intentionally causing injury and theft - Applicant suffers from several mental health conditions - Applicant on bridging visa at time of offending - Sentence moderated by Verdins principles - Whether judge failed to consider burden of imprisonment owing to prospect of mandatory deportation - Whether individual sentences for attempted aggravated carjacking and intentionally causing injury manifestly excessive - Leave to appeal refused.

Yusuf v DPP [2026] VSCA 130 (Opens in a new tab/window)

Walker and Whelan JJA
09 June 2026
Catchwords

CRIMINAL LAW - Application for leave to appeal sentence - Attempted armed robbery and possession of imitation firearm - Total effective sentence of 3 years and 6 months' imprisonment - Whether sentence manifestly excessive by reason of giving insufficient weight to principles of totality and parity - No substance in parity submission - Significance of time in custody not able to be declared as pre-sentence detention - Total time in custody to be factored into the sentencing synthesis - Judge fully aware of all relevant offending and sentences - Leave to appeal refused.

Restitution

A.M.O. Rifat Holdings Pty Ltd v Dib [2026] VSCA 124 (Opens in a new tab/window)

Niall CJ and Beach and Donaghue JJA
04 June 2026
Catchwords

RESTITUTION - Quantum meruit - Domestic building contract with divisible stages and equal instalments due upon the completion of each stage - Builder sought to recover fair value for partially completed stages - Amount of contractual entitlement to payment on completion of a stage is a 'cap' on amount recoverable, not a substitute for assessing the value of work done - Quantum meruit different to contractual damages - Builder's evidence incapable of establishing value of the work done for which there was no contractual entitlement to payment - Not in interests of justice to remit matter to Tribunal to allow builder to re-run case on different evidence - Leave to appeal refused - Mann v Paterson Constructions Pty Ltd (2019) 267 CLR 560; South Australian Harbors Board v South Australian Gas Co (1934) 51 CLR 485; Pavey & Matthews Pty Ltd v Paul (1987) 162 CLR 221, considered; University of Wollongong v Metwally [No 2] (1985) 59 ALJR 481, followed.

Constitutional law

1559 High Street Pty Ltd v Camillo Builders Pty Ltd [2026] VSCA 129 (Opens in a new tab/window)

McLeish and Kennedy and Kaye JJA
09 June 2026
Catchwords

CONSTITUTIONAL LAW - Inconsistency of laws - Whether s 109 inconsistency arises between ss 28M, 28O and 28R(1)-(5) of Building and Construction Industry Security of Payment Act 2002 ('SOP Act') and ss 18, 232, 234, 236 and/or 237 of Australian Consumer Law ('ACL') - Where respondent obtained judgment against applicant on basis of adjudication certificate under SOP Act - Where applicant claims that SOP Act provisions impaired its 'rights' to raise an ACL claim - Whether SOP Act provisions vary, detract from, or impair federal law - SOP Act creates novel statutory right separate and distinct from ACL rights - Rights operate concurrently - Application for leave to appeal granted - Appeal dismissed.

Supreme Court of Victoria Commercial Court

Consumer law

TM Insight Operations Pty Ltd v H.A.G. Import Corpn. (Australia) Pty Ltd [2026] VSC 346 (Opens in a new tab/window)

Delany J
03 June 2026
Catchwords

CONSUMER LAW - Misleading or deceptive conduct - Whether supplier of digital services made representations about retailer integration model - Whether representations as pleaded made - Necessary to identify with precision when representations made - Self Care IP Holdings Pty Ltd v Allergan Australia Pty Ltd (2023) 277 CLR 186, applied - Australian Consumer Law, ss 18, 29.

Equity

Re Shaw & Anor [2026] VSC 344 (Opens in a new tab/window)

Nichols J
04 June 2026
Catchwords

EQUITY - Judicial advice -Supreme Court (General Civil Procedure) Rules 2025 (Vic), r 54.02 - 'Beddoe Application': In re Beddoe, Downes v Cottam [1893] 1 Ch 547 - Jurisdiction of the court to provide advice - Factors relevant to discretion to provide advice - Degree of satisfaction required before the court should give advice - Macedonian Orthodox Community Church St Petka Inc v His Eminence Petar The Diocesan Bishop of The Macedonian Orthodox Diocese of Australia and New Zealand (2008) 237 CLR 66; Hopkins v Edwards (2020) 20 ASTLR 329; Re Care Super Pty Ltd [2021] VSC 805, applied - Discretion exercised not to give judicial advice.

Corporations

Re Aussky Construction Pty Ltd [2026] VSC 362 (Opens in a new tab/window)

Hetyey AsJ
11 June 2026
Catchwords

CORPORATIONS - Insolvency - Corporations Act 2001 (Cth) - s 588G - Insolvent trading - Undefended - s 588G(1) - Whether debts incurred when company insolvent - Whether reasonable grounds to suspect insolvency - s 588G(2) - Whether director aware of grounds to suspect insolvency - Whether reasonable person in like position would suspect insolvency - Failure to keep financial records as required by s 286(1) - Failure to retain financial records for 7 year period as required by s 286(2) - Presumption of insolvency under s 588E(4) enlivened - Actual insolvency under s 95A found - Reasonable grounds for suspecting insolvency found - s 588M - Order for compensation for loss suffered by creditors - Award of pre-judgment interest under s 58 of the Supreme Court Act 1986 (Vic) - Where 'good cause' to reduce award of interest where significant and unexplained delay between letter of demand and commencement of proceeding.

Re KPL Pty Ltd (in liq) [2026] VSC 312 (Opens in a new tab/window)

Steffensen AsJ
25 May 2026
Catchwords

CORPORATIONS - Insolvency - Application to remove liquidator - Whether liquidator has adequately investigated company's affairs - Whether liquidator has failed to advance the liquidation - No credible basis for removal of liquidator - Corporations Act 2001 (Cth) - Insolvency Practice Schedule (Corporations), s 90-15 - Re Gemwood Pty Ltd (in liq) [2025] VSC 819, applied.

Contract

MacDonald & Co v Kharty [2026] VSC 336 (Opens in a new tab/window)

Craig J
02 June 2026
Catchwords

CONTRACT - Whether common law right to terminate excluded by contractual show cause termination process - Contract permitted the plaintiff to terminate for 'substantial breach' following a show cause process - Plaintiff did not follow that process and purported to terminate at common law - Proper construction of contract required the Plaintiff to follow the contractual termination process except in cases of repudiation by 'renunciation' - Aggressive and threatening behaviour by Defendant constituted renunciation - Termination by Plaintiff therefore valid - Concut Pty Ltd v Worrell (2000) 75 ALJR 312; [2000] HCA 64, applied; Koompahtoo Local Aboriginal Land Council v Sanpine Pty Ltd (2007) 233 CLR 115, applied; Laurinda Pty Ltd v Capalaba Park Shopping Centre Pty Ltd (1989) 166 CLR 623, applied; Shevill v Builders Licensing Board (1982) 149 CLR 620, applied; Amann Aviation Pty Ltd v Commonwealth of Australia (1990) 22 FCR 527, discussed.

Landlord and tenant

Gliddon v Latham Professional Services Company Pty Ltd & Ors [2026] VSC 338 (Opens in a new tab/window)

Croft J
03 June 2026
Catchwords

LANDLORD AND TENANT - Lease or licence - Test - Right to exclusive possession - Oral agreement - Whether essential features of lease are made out - No sufficient certainty of terms of lease - No right to exclusive possession - Occupancy arrangement a contractual licence - Lewis v Bell (1985) 1 NSWLR 731 - United Petroleum Pty Ltd v Pentaco Oil (Aust) Pty Ltd [2016] FCA 118 - Pirie v Saunders (1961) 104 CLR 149 - BP Refinery (Westernport) Pty Ltd v Hastings Shire Council (1977) 180 CLR 266 - Swan v Uecker (2016) 50 VR 74 - Radaich v Smith (1959) 101 CLR 209 - Caltex Properties Ltd (in liq) v Love (1997) 95 LGERA 132 - Leadenhall Residential 2 Ltd v Sterling (CA) [2002] 1 WLR 499 - Stewart v Watts (Secretary of State for Communities and Local Government and others intervening) [2018] Ch 423 - Living and Leisure Australia Ltd v Commissioner of State Revenue [2017] VSC 675 - Western Australia v Ward (2002) 213 CLR 1.

Practice and procedure

Accelerated Loans v Kirby [2026] VSC 331 (Opens in a new tab/window)

Craig J
28 May 2026
Catchwords

PRACTICE AND PROCEDURE - Application by a lender for summary judgment against guarantor pursuant to s 63 Civil Procedure Act 2010 (Vic) - Order sought for possession of properties of guarantor provided by way of security - Plaintiff did not establish that Defendant had no real prospect of success - Application refused.

Façade Designs International Pty Ltd v Yuanda Vic Pty Ltd (No 5) [2026] VSC 352 (Opens in a new tab/window)

Cosgrave J
05 June 2026
Catchwords

PRACTICE AND PROCEDURE - Orders to be made giving effect to judgment - Where judgment given for the plaintiff - Where parties agreed to refer outstanding questions to special referee under O 50 of the Supreme Court (General Civil Procedure) Rules 2025 (Vic).

Re 452HM Pty Ltd (in liq) (recs and mgrs apptd) [2026] VSC 350 (Opens in a new tab/window)

Fary AsJ
05 June 2026
Catchwords

PRACTICE AND PROCEDURE - Consolidated proceedings - Owners corporation dispute - Matters transferred from the Victorian Civil and Administrative Tribunal - Where issues substantially overlap - Competing applications - Matters heard and determined together.

Supreme Court of Victoria Common Law Division

Open courts

XY v Independent Broad-based Anti-corruption Commission [2026] VSC 299 (Opens in a new tab/window)

Harris J
22 May 2026
Catchwords

OPEN COURTS - Application for pseudonym order.

Administrative law

McLindon v Minister for Local Government [2026] VSC 355 (Opens in a new tab/window)

Moore J
09 June 2026
Catchwords

ADMINISTRATIVE LAW - Judicial review - Suspension of councillor by Governor in Council on recommendation of Minister - Statutory conditions for making recommendation under s 229A Local Government Act 2020 (Vic) - Statutory functions of municipal monitors - Report by municipal monitors to Minister that plaintiff creating serious risk to the health and safety of councillors or staff - Minister satisfied that plaintiff creating a serious risk to the health and safety of councillors and staff - Meaning of serious risk to health and safety - Allegations of bias and abuse of process - Denial of procedural fairness by municipal monitors - Failure by municipal monitors to comply with s 181C of the Local Government Act 2020 (Vic) invalidated report - Statutory condition for Minister's recommendation not fulfilled - Considerations of appropriate relief - Declaratory relief granted - Local Government Act 2020 (Vic) ss 180, 181C, 229A - Djokovic v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs (2022) 289 FCR 21 - Minister for Immigration and Ethnic Affairs v Wu Shan Liang (1996) 185 CLR 259 - Applicant VEAL of 2002 v Minister for Immigration and Multicultural and Indigenous Affairs (2005) 225 CLR 88 - Project Blue Sky Inc v Australian Broadcasting Authority (1998) 194 CLR 355 - Attorney- General (Tas) v Casimaty (2024) 98 ALJR 1139 - Wingfoot Australia Partners Pty Ltd v Kocak (2013) 252 CLR 480 - Ainsworth v Criminal Justice Commission (1992) 175 CLR 564 - Victorian Taxi Families Inc and Redfield Court Holdings Pty Ltd v Commercial Passenger Vehicle Commission [2020] VSC 762.

Toll Holdings Limited v Sutcliffe [2026] VSC 339 (Opens in a new tab/window)

Goulden AsJ
04 June 2026
Catchwords

ADMINISTRATIVE LAW - Application, made out of time, for review of medical panel opinion under Order 56 of the Supreme Court (General Civil Procedure) Rules 2025 (Vic) - Medical Panel convened under the Workplace Injury Rehabilitation and Compensation Act 2013 (Vic) ('WIRC Act') - Medical Panel amended certificate of opinion because of a 'slip' - Amended opinion said to be affected by jurisdictional error and/or error of law on the face of the record as opinion was not open or legally unreasonable - Asserted failure to give adequate reasons sufficient to comply with s 313 of the WIRC Act - Whether relief should be refused on discretionary grounds because of conduct of plaintiff and because futile and causing no practical injustice - Whether special circumstances exist to grant extension of time - No special circumstances - No jurisdictional error or failure to give adequate reasons - Relief would be refused on discretionary grounds - Proceeding dismissed.

Wells v D'Silva [2026] VSC 329 (Opens in a new tab/window)

Quigley J
29 May 2026
Catchwords

ADMINISTRATIVE LAW - Appeal from Victorian Civil and Administrative Tribunal - Self-represented litigant - Residential tenancy - Rental provider's intention to sell with vacant possession - Refusal to vacate - Bona fides of the notice to vacate in issue before the Tribunal - Possession order made - Whether denial of procedural fairness in hearing - Whether fair opportunity to respond to documents referred to during hearing - Whether refusal of adjournment procedurally unfair - Whether 'reasonable and proportionate' to make the possession order in the circumstances - Whether Tribunal properly considered considerations relevant under section 330A of the Residential Tenancies Act 1997 (Vic) - Whether legally sufficient evidence for material findings made - Adequacy of reasons - Leave to appeal - Leave to appeal partially granted - Appeal dismissed.

Appeal

Maple Media Pty Ltd v Monash City Council [2026] VSC 330 (Opens in a new tab/window)

Gray J
29 May 2026
Catchwords

APPEAL - PLANNING AND ENVIRONMENT - Application for leave to appeal from decision and orders of the Victorian Civil and Administrative Tribunal - Planning permit for development of land by construction and/or putting up for display of 'major promotion signs' - Permit referred to permission for the 'installation and display' of major promotion signs - Permit included a condition stating permit would expire 15 years after issue - Permit did not otherwise include a condition requiring completion of construction by a particular time - Completion of construction of signs took longer than two years from issue of permit - Responsible authority asserted that permit had expired - Permit holder applied for declaration by VCAT - VCAT refused to make declaration that permit had not expired - Whether s 68(1)(b) of the Planning and Environment Act 1987 caused permit to expire - Whether permit specified a time for completion of the development displacing default expiry under s 68(1)(b) - Principles guiding interpretation of planning permit - On its proper interpretation taking into account all its elements the permit specified a time of 15 years for completion of development - VCAT erred in refusing to make declaration that the permit had not expired - Victorian Civil and Administrative Tribunal Act 1998 s 148 - Planning and Environment Act 1987 ss 62(1), 68(1)(b) - Monash Planning Scheme cl 52.05.

Interest

Environment Protection Authority Victoria v Landfill Operations Pty Ltd (No 2) [2026] VSC 356 (Opens in a new tab/window)

Harris J
05 June 2026
Catchwords

INTEREST - When interest falls due on a debt for landfill levy under the Environment Protection Act 1970 (Vic) - Debt arising from an invoice found to be a notice issued under s 50X(4) of the Environment Protection Act 1970 (Vic) - Section 50X(4) notice is to be paid within 30 days.

Administration and probate

Condon v Smith [2026] VSC 360 (Opens in a new tab/window)

Goulden AsJ
09 June 2026
Catchwords

ADMINISTRATION AND PROBATE - Application to remove executor and trustee of deceased's estate - Administration and Probate Act 1958, s 34 - Trustee Act 1958, s 48 - Whether executor unfit to remain in office - Application for indemnity costs against defendant.

Lihoudis v Lihoudis [2026] VSC 367 (Opens in a new tab/window)

Goulden AsJ
11 June 2026
Catchwords

ADMINISTRATION AND PROBATE - Application to remove executor and trustee of deceased's estate - Administration and Probate Act 1958, s 34 - Trustee Act 1958, ss 48, 51 - Whether executor and trustee unfit to remain in office - Application for indemnity costs against defendant.

Practice and procedure

Catherine Sayers v Luke Sayers [2026] VSC 332 (Opens in a new tab/window)

Watson J
03 June 2026
Catchwords

PRACTICE AND PROCEDURE - Cross-vesting application - Application by defendant to transfer Supreme Court proceeding to the Victorian Registry of the Federal Circuit and Family Court of Australia - Not in interests of justice to transfer the proceeding - Defamation proceeding performs an important function of public vindication for a successful party - Open court default position in this jurisdiction - Supreme Court more appropriate forum to consider novel privacy tort - Capacity to provide trial expeditiously - Application dismissed - Jurisdiction of Courts (Cross-vesting) Act 1987 (Vic) s 5(1); Courts (Cross-vesting) Act 1987 (Cth) s 9(3) - Re Wakim; Ex parte McNally (1999) 198 CLR 511; Irwin v State of Queensland [2011] VSC 291 applied.

Chalker v Baldwin [2026] VSC 335 (Opens in a new tab/window)

Tsalamandris J
03 June 2026
Catchwords

PRACTICE AND PROCEDURE - Appeal from the ruling of a judicial registrar - Application for extension of time - Setting aside of subpoenas - Recusal application - Timetabling orders - No merit in appeal - Extension of time not granted - Appeal dismissed.

He v Wang [2026] VSC 357 (Opens in a new tab/window)

Ierodiaconou AsJ
03 June 2026
Catchwords

PRACTICE AND PROCEDURE - Judicial Review - Commencement of proceeding out of time - Application for extension of time - Whether 'special circumstances' existed - Extension of time granted.

Skordakis v Victorian Building Authority (Ruling) [2026] VSC 342 (Opens in a new tab/window)

Gray J
03 June 2026
Catchwords

PRACTICE AND PROCEDURE - Leave to amend notice of appeal - Real question or controversy between the parties - Supreme Court (General Civil Procedure) Rules 2025 ord 36 - Abuse of process - Public interest - Civil Procedure Act 2010 ss 7-9 - Question of law as to whether Tribunal had jurisdiction to hear and determine the matter - Thurin v Krongold Constructions (Aust) Pty Ltd (2022) 73 VR 403; (2022) 407 ALR 187; [2022] VSCA 226 - Contingent order relating to the costs of the Tribunal proceeding sought by way of condition on any grant of leave - Premature to make any order relating to costs of the Tribunal proceeding - Victorian Civil and Administrative Tribunal Act 1998 s 148 - Supreme Court Act 1986 s 24 - Aon Risk Services Australia Ltd v Australian National University (2009) 239 CLR 175; [2009] HCA 27 - Australian Education Union v Lawler (2008) 169 FCR 327; [2008] FCAFC 135.

Civil procedure

Butera v Cedarvale Pty Ltd (implied undertaking) [2026] VSC 327 (Opens in a new tab/window)

Harris J
28 May 2026
Catchwords

CIVIL PROCEDURE - Obligation not to use documents produced under compulsion in a proceeding other than for the purposes of that proceeding - Prohibition in s 27 of the Civil Procedure Act 2010 (Vic) on use of documents disclosed in compliance with s 26 for a purpose other than in connection with the civil proceeding - Application for release from the implied undertaking and release from obligations in s 27 of the Civil Procedure Act 2010 (Vic) - Retrospective or nunc pro tunc relief - Appropriate procedure for application - Civil Procedure Act 2010 (Vic) ss 26, 27.

Assessment of damages

Barr Corporation Pty Ltd v Roff [2026] VSC 334 (Opens in a new tab/window)

Goulden AsJ
02 June 2026
Catchwords

ASSESSMENT OF DAMAGES - Judgment in default of appearance entered against first defendant - Judgment by consent against second defendant - Assessments of damages - No appearances on assessments by first or second defendant, despite notice.

Supreme Court of Victoria Criminal Division

Bail

Re Warsame [2026] VSC 324 (Opens in a new tab/window)

O'Connell J
02 June 2026
Catchwords

CRIMINAL LAW - Application for bail - Charge of murder - Deceased shot in context of ongoing conflict between youth gangs - Requirement to show exceptional circumstances - Applicant 19 years of age - No previous criminal convictions - Stable accommodation and employment - Significant bail guarantee - Nature and seriousness of alleged offending - Whether prosecution case 'fatally weak' - Prospective delay - Whether applicant's ill health able to be adequately managed in custody - Exceptional circumstances not established - Bail refused - Bail Act 1977 (Vic), ss 1B, 3, 3AAA, 4A.

Criminal law

DPP v DJD (Sentence) [2026] VSC 341 (Opens in a new tab/window)

Incerti J
03 June 2026
Catchwords

CRIMINAL LAW - Sentence - Make threat to kill - Threat to commit sexual offence - Three charges of failing to comply with a supervision order - One charge of committing an indictable offence whilst on bail - Summary jurisdiction application - Plea of guilty - Verdins and moral culpability - Total effective sentence of 10 months' imprisonment - Serious Offenders Act 2018 (Vic) ss 169, 173, 174.

DPP v SJW [2026] VSC 347 (Opens in a new tab/window)

Champion J
29 May 2026
Catchwords

CRIMINAL LAW - Sentence - Two charges of contravening a condition of a supervision order - Prohibited gambling - Prohibited use of methyl amphetamine and diazepam - Plea of guilty - Prior convictions for similar offending - Sentencing Act 1991 (Vic) ss 83A, 113, 113B - Serious Offenders Act 2018 (Vic) ss 169, 173, 174, 229.

Re Clarke (No 1) [2024] VSC 696 (Opens in a new tab/window)

Jane Dixon J
12 November 2024
Catchwords

CRIMINAL LAW - Change of venue application - Pre-trial ruling - Aboriginal accused - Significant mental health considerations - Application granted - Criminal Procedure Act 2009 s 192 - DPP v Bennett (2004) 10 VR 355; R v Iaria and Panozzo (2004) 9 VR 425.

Re Clarke (No 2) [2024] VSC 697 (Opens in a new tab/window)

Jane Dixon J
12 November 2024
Catchwords

CRIMINAL LAW - Murder - Joint trial of co-accused - Separate trial application - Whether the evidence of a witness who allegedly received a confession from Clarke is impermissibly bolstered by Hill's out-of-court statements - Whether risk of substantial prejudice - Whether amenable to judicial directions - Application refused - Criminal Procedure Act 2009 ss 170(2), 193(2), 193(3) - R v Demirok [1976] VR 244 - R v Gibb and McKenzie [1983] 2 VR 155 - R v Jones & Waghorn (1991) 55 A Crim R 159 - R v Iaria and Panozzo (separate trial) [2004] VSC 110 - R v Vollmer (1996) 1 VR 95 - Young v R [2015] VSCA 265 - R v Mwamba [2015] VSCA 338 - Feeney v The Queen [2022] VSCA 113 - DPP v Bottom & Ors (Ruling No 2) [2022] VSC 401 - R v Kannan & Anor (Ruling No 12) [2021] VSC 39.

Re Clarke (No 3) [2025] VSC 174 (Opens in a new tab/window)

Jane Dixon J
04 April 2025
Catchwords

CRIMINAL LAW - Murder - Pre-trial ruling - Evidence - Admissibility of alleged admissions to [relative] of accused - Evidence admissible - Evidence Act 2008 ss 90, 137, 138 and residual common law ('Haddara') discretion - Ridley v The King [2024] VSCA 308 - Haddara v R (2014) 43 VR 53.

Re TL [2026] VSC 353 (Opens in a new tab/window)

Forbes J
04 June 2026
Catchwords

CRIMINAL LAW - Application under Sex Offenders Registration Act 2004 to have reporting obligations of sex offending suspended - Applicant sentenced in 2009 and became registrable offender for life - Applicant's reporting obligations suspended in 2023 by the Chief Commissioner of Police pursuant to s 45A SORA - Low risk to the sexual safety of one or more persons or the community - In public interest to grant application - Application not opposed by Chief Commissioner of Police - Sex Offenders Registration Act 2004, ss 39, 40, 45A.

County Court of Victoria

Practice and procedure

Weir & Ors v Xantias Financial Management Pty Ltd & Anor [2026] VCC 760 (Opens in a new tab/window)

Judicial Registrar Umbers
29 May 2026
Catchwords

PRACTICE AND PROCEDURE - Application for summary enforcement of a settlement deed - Whether the doctrine of substantial performance applies in the context of breach of settlement terms - Whether the innocent party's delay in seeking summary enforcement constitutes waiver of rights - No irrevocable consent to judgment in settlement terms - Roberts jurisdiction.

Summary judgment

The Trust Company (Australia) Limited v Hutchinson & Anor [2026] VCC 759 (Opens in a new tab/window)

Judge Wise
29 May 2026
Catchwords

SUMMARY JUDGMENT - Guarantees - Construction loan - Guarantors' obligation to repay money owing by a borrower under limited guarantee - Whether lender able to enforce guarantee while borrower's liquidator is recovering from third parties - Whether lender's application of repayments and sale proceeds from security property to monies outstanding under loan reduces the maximum limit of guarantee - Whether lender breached obligations as mortgagee in possession.

Legislation

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