Library Bulletin

From the Director

Victorian Court of Appeal

Courts and judges

Millsave Holdings v Connective Services [2025] VSCA 342 (Opens in a new tab/window)

McLeish and Lyons JJA
19 December 2025
Catchwords

COURTS AND JUDGES - Orders after judgment remitting matter to associate judge - Determination of fair value - Valuation as at date of order of associate judge - Whether order requires working out - Whether order needing clarification - Liberty to apply not reserved - Whether Court of Appeal has power to vary order - Whether order should be varied in any event - Application to vary order dismissed.

Corporations

Mayfair Land Holdings Pty Ltd v Terafortis Ltd [2025] VSCA 343 (Opens in a new tab/window)

Walker and Orr and Kenny JJA
22 December 2025
Catchwords

CORPORATIONS - Appeal - Statutory demand - Application to set aside demand - Whether plausible contention requiring further investigation as to genuine dispute - Whether plausible contention requiring further investigation as to debt amount - Whether plausible contention requiring further investigation that respondent acted unconscionably in recovering debt while negotiations were ongoing - No plausible contention established by applicant's evidence - Leave to appeal refused.

Appeal

Mallard v Homes Victoria [2025] VSCA 339 (Opens in a new tab/window)

Niall CJ and Kennedy JA and J Forrest AJA
19 December 2025
Catchwords

APPEAL - Administrative Law - Decision of Homes Victoria to redevelop public housing towers in Melbourne - Representative proceeding brought by resident seeking judicial review of decision - Judicial review proceeding dismissed - Procedural fairness - Nature of power - Whether decision affected legally recognised right or interest - Content of procedural fairness obligation - Materiality - No obligation to afford procedural fairness - Leave to appeal granted - Appeal dismissed.

Practice and procedure

MacDonald v Grundy [2025] VSCA 340 (Opens in a new tab/window)

Orr JA
19 December 2025
Catchwords

PRACTICE AND PROCEDURE - Extensions of time - Self-represented applicant in protracted dispute with former lawyers over non-payment of legal fees and with executors of his late mother's estate about his distribution from estate - Whether applicant denied procedural fairness - Whether judge erred in determining no utility to grant extensions of time to appeal self-executing orders dismissing proposed appeals from decisions of Magistrate on basis that the proposed appeals from decisions of Magistrate had no prospects of success - Applications for leave to appeal totally without merit - Leave to appeal refused

Landlord and tennant

Kumaran v Bakowli [2025] VSCA 336 (Opens in a new tab/window)

Beach JA
19 December 2025
Catchwords

LANDLORD AND TENNANT - Residential rental agreement - Order made by VCAT that tenant pay landlord compensation for unpaid rent and other costs incurred by landlord - Application for extension of time within which to seek leave to appeal from VCAT orders - Whether judge erred in refusing application for extension of time - Whether VCAT erred in law - Whether VCAT made jurisdictional error - Whether VCAT denied applicant procedural fairness - Applicant not establishing any error or denial of procedural fairness or bias on the part of VCAT - Proposed appeal having no prospects of success - Application for leave to appeal totally without merit - Application for leave to appeal refused.

Torts

Gobel Aviation Pty Ltd (in liq) v Ripper [2025] VSCA 344 (Opens in a new tab/window)

Niall CJ and Beach JA and O'Meara AJA
23 December 2025
Catchwords

TORTS - Appeal - Personal injury - Negligence - Plane crash during solo flying assessment - Whether aircraft under control of student and/or instructor - Whether instructor's negligence was a cause of plane crash - Whether plane crash solely the fault of student pilot - Whether judge made findings against weight of evidence - Evidence - Whether judge erred in accepting plaintiff's evidence in circumstances where judge found plaintiff's evidence unsatisfactory - No error in judge's analysis - Leave to appeal granted - Appeal dismissed.

Criminal law

DPP v Gluyas; Gluyas v The King [2025] VSCA 335 (Opens in a new tab/window)

Boyce and Kidd JJA and J Forrest AJA
18 December 2025
Catchwords

CRIMINAL LAW - Application for leave to appeal - Conviction - Applicant sentenced to 5 months' imprisonment (aggregate sentence) combined with a 2-year community correction order for one charge of aggravated burglary and two charges of theft (including theft of motor vehicle) with co-offenders - Applicant pleaded guilty after sentence indication hearing - Director appealed sentence on basis of manifest inadequacy - Application for leave to appeal against conviction instituted after applicant informed by the Court of Appeal that he was at risk of increase in sentence - Whether triable issues - Whether guilty plea freely made or improperly induced - Whether substantial miscarriage of justice - Plea freely and voluntarily made - Application for extension of time granted - Leave to appeal granted - Appeal dismissed.

Costs

Akers v Victoria Police [2025] VSCA 341 (Opens in a new tab/window)

Beach JA
22 December 2025
Catchwords

COSTS - Appeal - Application for extension of time within which to seek leave to appeal against costs order - Application for leave to appeal against costs order - Proposed appeal having no prospect of success - No adequate explanation for delay - Application for leave to appeal totally without merit - No basis for granting extension of time - Applications dismissed.

Copper (Qld) Investment Pte Ltd v Hallion (No 2) [2025] VSCA 338 (Opens in a new tab/window)

Beach and Walker and Kenny JJA
19 December 2025
Catchwords

COSTS - Mortgages - Mortgagee's entitlement to costs under general law and rules of court - Whether costs discretion should be exercised in accordance with contract - Where mortgagor alleged mortgagee invalidly appointed receivers - Mortgagee successful at trial but on appeal receivers found to be invalidly appointed - Mortgagee awarded 75 percent of costs of trial - Contract excluded mortgagee's liability for 'attempted' or 'purported' exercise of power - Contract indemnified mortgagee for 'exercise or attempted' exercise of power - Mortgagee rejected Calderbank offers - Costs in the Court's discretion - Orders for trial costs set aside - Mortgagee ordered to pay 25 percent of trial costs - No order for costs of appeal.

Supreme Court of Victoria Commercial Court

Appeal

Select Harvests Pty Ltd v Jose Borrell S.A. [2025] VSC 839 (Opens in a new tab/window)

Delany J
23 December 2025
Catchwords

APPEAL - Appeal against decision of associate justice - Contract - Interpretation - Governing law and jurisdiction clause - Whether exclusive jurisdiction clause - Whether clause ambiguous or a 'nonsense' - Appeal dismissed.

Costs

Re Norstar Recycling Pty Ltd (No 2) [2025] VSC 841 (Opens in a new tab/window)

Waller J
23 December 2025
Catchwords

COSTS - Interlocutory injunction application dismissed - Whether costs should follow the event - Whether costs should be assessed on indemnity basis - Whether costs should be taxed immediately - Plaintiff failed to establish serious question to be tried - Defendants' use of confusing 'unpaid dividends' terminology and late disclosure of novation argument - Whether defendants' conduct amounts to disentitling conduct - Whether plaintiff acted in wilful disregard of known facts or when properly advised should have known application had no chance of success - Complex transactions requiring expert analysis - Whether plaintiff's conduct demonstrates want of competence and diligence - Pleadings not yet filed - Relationship between interlocutory application and substantive proceeding unclear - Costs ordered against plaintiff on standard basis to be taxed at conclusion of proceeding - Supreme Court (General Civil Procedure) Rules 2025 (Vic) rr 63.20, 63.20.1 - Supreme Court Act 1986 (Vic) s 24(1).

Corporations

Re Gemwood Projects Pty Ltd (in liq) [2025] VSC 819 (Opens in a new tab/window)

Croft J
19 December 2025
Catchwords

CORPORATIONS - Insolvency- Statutory presumption of insolvency - Commercial realities - Related party funding - Where lending entity has same controlling mind as the company - Whether ongoing intention to fund all liabilities exists - Where loaned monies not subject to written contract with repayment terms - Whether loaned monies is characterised as a short or long-term liability - Australian Securities and Investment Commission v Plymin (2003) 175 FLR 124 - Southern Cross Interiors v Deputy Commissioner of Taxation (2001) 53 NSWLR 213 - Canstruct Pty Ltd v Project Sea Dragon (2024) 172 ACSR 73 - Sandell v Porter (1966) 115 CLR 666 - Corporations Act 2001 ss 95A; 286 - Lending entity ready and willing to fund liabilities at all times - No insolvency.

Corporations law

Re Caydon MP No 1 Development Pty Ltd (in liq) (recs and mgrs apptd) [2025] VSC 803 (Opens in a new tab/window)

Gobbo AsJ
19 December 2025
Catchwords

CORPORATIONS LAW - Application by liquidator under s 588FF(3)(b) of the Corporations Act 2001 (Cth) for extension of time for making any application under s 588FF(1) - Extension sought to allow liquidator to review material provided by putative creditor and to form a view as to the potential claims identified by putative creditor - Application opposed by interested parties - Consideration of prejudice and delay - Unexplained delay - No evidence as to merits - Presumptive prejudice - Actual prejudice - Whether shelf order appropriate - Turns on own facts - Application refused.

Real property

Owners Corporation Plan No. SP020966P v Memart Investments Pty Ltd [2025] VSC 818 (Opens in a new tab/window)

Croft J
19 December 2025
Catchwords

REAL PROPERTY - Acquisition of land - Adverse possession - Standing to sue - Lease to incorporated association - Upon deregistration of incorporated association property vested in Registrar of Incorporated Associations - Breach of lease due to deregistration - Notice of default and termination of Lease - Continued use by Owners Corporation and its members - Construction of Agreement to Lease and Lease - Proprietary estoppel - Conventional estoppel - Owners Corporation Act 2006, ss 3, 4, 6, 15, 18 - Associations of Incorporation Reform Act 2012, ss 140, 142, 143, 187(1) - Associations Incorporation Act 1981, ss 3, 36E, 36F - Limitations of Actions Act 1958, ss 5, 8, 14 - Property Law Act 1958, s 139 - Transfer of Land Act 1958, s 42 - Coulls v Bagot's Executor & Trustee Co Ltd (1967) 119 CLR 469 - Trident General Insurance Co Ltd v McNiece Bros Pty Ltd (1988) 165 CLR 107 - Des Barres v Shey (1873) 29 LT (NS) 592 - Ramnarace v Lutchman [2001] 1 WLR 1651 - Powell v McFarlane (1979) 38 P&CR 452 - Whittlesea City Council v Abbatangelo (2009) 259 ALR 56 - Eckford v Stanbroke Pastoral Co Pty Ltd (2012) 2 Qd R 323 - Sowler v Potter [1940] 1 KB 271 - Harvey v Pratt [1965] 1 WLR 1025 - Gurappaji v Duncan [2023] VSC 558 - Taylors Fashions Ltd v Liverpool Trustees Co Ltd [1982] QB 133 - Crown Melbourne Ltd v Cosmopolitan Hotel (Vic) Pty Ltd (2016) 260 CLR 1 - Ryledar Pty Ltd v Euphoric Pty Ltd (2007) 69 NSWLR 603.

Legal practitioners

Kurtz & Son Development (Nominees) Pty Ltd & Ors v Helen Jankie [2025] VSC 817 (Opens in a new tab/window)

Craig J
19 December 2025
Catchwords

LEGAL PRACTITIONERS - Application by defendant to restrain firm from continuing to act for plaintiffs - Whether firm should cease to act for clients where solicitor likely to give evidence as a material witness - Whether solicitor has a 'personal stake' in the proceedings - Inherent jurisdiction of Court over its officers and to control its processes - Presently low risk of inconsistency between evidence of solicitor and evidence or claim of clients - Low risk of relevant conflict - Discretionary factors weigh against restraint.

Practice and procedure

Doug Pascoe Investments Pty Ltd & Ors v Urban Cube Pty Ltd & Ors (No 2) [2025] VSC 809 (Opens in a new tab/window)

Matthews J
18 December 2025
Catchwords

PRACTICE AND PROCEDURE - Application for summary enforcement of a settlement agreement to resolve a proceeding - Roberts v Gippsland Agricultural & Earth Moving Contracting Co [1956] VLR 555 applied - Court must be satisfied justice can be done via summary procedure - Seachange Management Pty Ltd v Pital Business Pty Ltd (2009) 23 VR 396 applied - Bell v Knight 34 Langdon Road Pty Ltd [2022] VSC 497 applied - Re RM Road Services Pty Ltd (in liq) & Ors (No 2) [2025] VSC 382 followed - Application granted.

Redbar Plant Hire Pty Ltd v Barker [2025] VSC 789 (Opens in a new tab/window)

Gitsham JR
19 December 2025
Catchwords

PRACTICE AND PROCEDURE - Interpleader proceedings under Order 12 of the Supreme Court (General Civil Procedure) Rules 2025 (Vic) - Expectation of being sued - Collusion - Interpleader relief refused.

Supreme Court of Victoria Common Law Division

Open Courts Act 2013

WEQ (a pseudonym) v Medical Board of Australia (No 2) [2025] VSC 835 (Opens in a new tab/window)

Quigley J
19 December 2025
Catchwords

OPEN COURTS ACT 2013 - Documents released by Family Court of Australia on condition of confidentiality - Referral to regulator by Family Court - Interim proceeding suppression orders made - Application by regulator for permanent orders - Whether orders proposed are 'necessary' for the proper administration of justice - Risk of 'chilling effect' on notifiers - Where conflicting considerations arise in different jurisdictions - Inherent jurisdiction to make anonymisation orders and closed file orders - Whether proceeding suppression order appropriate in the circumstance - Greater limitation to the scope of order than previously judicially considered - Closed file order made - Non-publication order considered - Modified form of reasons for judgment published - Pseudonym orders maintained.

Wills and estates

Re the will of William Ian Southey [2025] VSC 801 (Opens in a new tab/window)

Goulden AsJ
19 December 2025
Catchwords

WILLS AND ESTATES - Principal beneficiary of estate does not exist in the manner contemplated by the deceased, or at all - Applicability of Re Benjamin; Neville v Benjamin [1902] 1 Ch 723 - Construction and effect of testamentary disposition - Gift to principal beneficiary ineffective - Where non-existence of principal beneficiary not expressed as contingency for gift over - Whether gift over saved by the rule in Jones v Westcomb (1711) Prec Ch 316 - Where gift over saved.

Re Yan; Hughes v Wong (No 4) [2025] VSC 833 (Opens in a new tab/window)

Kaye JA
22 December 2025
Catchwords

WILLS AND ESTATES - Judicial advice - Plaintiff acting in capacity as administrator ad colligendum bona of estate - Advice sought on proposed partial implementation of agreement between First and Second Defendants and the Estate - Agreement reached following judicial mediation with all parties in 2019 - Plaintiff has obtained independent legal and taxation advice on proposed implementation - Proposal within plaintiff's powers as administrator - Implementation of agreement not improper exercise of plaintiff's powers.

Practice and procedure

Harkin v Vapold Pty Ltd [2025] VSC 814 (Opens in a new tab/window)

Keogh J
18 December 2025
Catchwords

PRACTICE AND PROCEDURE - Alleged breach of trust - Application for summary judgment - Application to restrain solicitor from acting - Notices to produce documents - Whether conduct inconsistent with claim for privilege being maintained - Application to restrain solicitor from acting dismissed - Application for summary judgment dismissed - Paragraphs of statement of claim struck out - Plaintiff given opportunity to replead.

He v Monash University (Security for Costs) [2025] VSC 842 (Opens in a new tab/window)

Hetyey AsJ
19 December 2025
Catchwords

PRACTICE AND PROCEDURE - Security for costs - Application against natural person - Supreme Court (General Civil Procedure) Rules 2025 (Vic) - r 62.02(1)(f) - Inherent jurisdiction to award security - Whether impecuniosity established - Whether real risk that costs order will be unenforceable - Where previous unpaid costs orders - Where respondent seeks stay of appeal pending payment of security sum together with payment of taxed costs in related proceeding - Security for costs refused.

Re the Estate of Whiteman (deceased) (costs judgment) [2025] VSC 370 (Opens in a new tab/window)

Irving AsJ
25 June 2025
Catchwords

PRACTICE AND PROCEDURE - Costs - Executor's application for costs from the estate of the deceased in circumstances where the application for executor's commission under s 65 of the Administration and Probate Act 1958 (Vic) was refused - Rule 10.10 of the Supreme Court (Administration and Probate) Rules 2023 (Vic) - Rules 63.01 and 63.26 of the Supreme Court (General Civil Procedure) Rules 2015 (Vic) - Application refused - Second plaintiff to bear own cost and to pay costs of the first plaintiff's costs of the second plaintiff's application for executor's commission on a standard basis without indemnity from the deceased's estate.

Administrative law

Foenander v Monash Health & Ors [2025] VSC 823 (Opens in a new tab/window)

Garde J
19 December 2025
Catchwords

ADMINISTRATIVE LAW - Judicial review - Opinion of a Medical Panel - Whether the Medical Panel committed jurisdictional error - Whether the Medical Panel failed to have regard to a mandatory relevant consideration - Whether the Medical Panel failed to set out a path of reasoning which would enable a court to see whether the opinion does or does not involve any error of law - Wingfoot Australia Partners Pty Ltd v Kocak (2013) 252 CLR 480 - Victorian Workcover Authority v Putrus [2023] VSCA 28 - Victorian Workcover Authority v Jamali [2023] VSCA 240 - Sidiqi v Kotsios [2021] VSCA 187 - Mutual Cleaning and Maintenance Pty Ltd v Stamboulakis (2007) 15 VR 649 - Colquhoun v Capitol Radiology Pty Ltd (2013) 39 VR 296 - Ayana v Qantas Airways Ltd [2021] VSC 500 - Khayyerzadeh v Gibbons [2023] VSC 647 - Sahin v Victorian Workcover Authority [2024] VSC 241 - Khan v Romas [2017] VSC 731 - Bhelley v Coles Supermarkets Australia Pty Ltd [2022] VSC 446 - Wrongs Act 1958 Pt VBA ss 28LB, 28LF, 28LH, 28LJ, 28LL, 28LN, 28LWE, 28LZ, 28LZH, and 28LZI.

Mazi v Kao (No 2) (Notice of Rent Increase) [2025] VSC 598 (Opens in a new tab/window)

Finanzio J
07 October 2025
Catchwords

ADMINISTRATIVE LAW - Appeal from orders of Victorian Civil and Administrative Tribunal (VCAT) in a proceeding under Residential Tenancies Act 1997 (Vic) - Application for extension of time - Extension of time granted - Where residential rental provider gave renter a notice of proposed rent increase under s 44(1) - Where renter believed notice to be invalid and asked VCAT to set it aside - Where renter's application included a request for compensation which was not maintained at the hearing - Where VCAT dismissed the application on the basis of having no jurisdiction to make the order sought - Whether VCAT had jurisdiction to hear an application for an ancillary order in the absence of an application for a substantive order - Where no jurisdiction to make such an order - Leave to appeal allowed - Appeal dismissed.

Appeal

Fang v Owners Corporation No. RP001311 [2025] VSC 827 (Opens in a new tab/window)

Forbes J
19 December 2025
Catchwords

APPEAL - Victorian Civil and Administrative Tribunal decision - Dispute as between owners corporation and owner of one of four lots with shared common property - Determination by VCAT that owner remove external CCTV cameras, awning, relocate external component of air conditioning unit installed on her lot and pay civil penalty - Leave to appeal refused - Owners Corporations Act 2006 (Vic) - Victorian Civil and Administrative Tribunal Act 1998 (Vic) s 148(2A) - Shearman v Owners Corporation No 1 417405X [2016] VSC 551 - Franklin v Ubaldi Foods Pty Ltd [2005] VSCA 317.

WEQ (a pseudonym) v Medical Board of Australia [2025] VSC 767 (Opens in a new tab/window)

Quigley J
09 December 2025
Catchwords

APPEAL - Appeal from the Tribunal - Section 148 of the Victorian Civil and Administrative Tribunal Act 1998 (Vic) - Medical practitioner - Referral to the Tribunal by Medical Board under section 193 of Health Practitioner Regulation National Law - Disciplinary proceedings for professional misconduct or unprofessional conduct - Appeals from Tribunal's interlocutory and final orders - Whether Tribunal exercising federal jurisdiction - Tribunal not exercising legislative or judicial function in determining disciplinary proceeding under the National Law - Whether the Tribunal acted without jurisdiction in reliance on evidence before the Family Court of Australia - Documents released by Family Court order - Whether a Medical Board referral to the Tribunal was based on unlawfully obtained evidence - Admissibility of evidence and the rules of evidence at the discretion of the Tribunal - Effect of interlocutory orders subsumed by appeal against final orders - Procedural fairness - No error established - No real prospect of success - Leave to appeal refused.

Police

Application by the Chief Commissioner of Victoria Police under section 21B of Part 3A of the Terrorism (Community Protection) Act 2003 [2025] VSC 832 (Opens in a new tab/window)

Harris J
19 December 2025
Catchwords

POLICE - Terrorism - Statute empowering Supreme Court to authorise exercise of special powers to ensure the safety of persons attending event - Whether authorisation reasonably necessary to ensure the safety of persons attending event - Terrorism (Community Protection) Act 2003 (Vic), Part 3A, s 21.

Costs

Animals Australia Federation v CA Sinclair Proprietary Limited (Costs) [2025] VSC 830 (Opens in a new tab/window)

Keogh J
19 December 2025
Catchwords

COSTS - Plaintiff wholly unsuccessful in proceeding - Where plaintiff opposed order to pay second defendant's costs - Whether reduction in costs due to defendants' common interest in proceeding - Order that plaintiff pay second defendant's costs - No order as to reduction of costs.

Supreme Court of Victoria Criminal Division

Bail

Re Joannou [2025] VSC 824 (Opens in a new tab/window)

Elliott J
19 December 2025
Catchwords

CRIMINAL LAW - Application for bail - Schedule 1 offence - Requirement to show exceptional circumstances - Nature and seriousness of alleged offending - Strength of prosecution case - Personal circumstances - Special vulnerability - Dependants in need of support - Availability of treatment services - Availability of employment - Offers of bail guarantees - Exceptional circumstances established - Whether applicant an unacceptable risk - Risk not shown to be unacceptable if bail granted on strict conditions - Bail granted - Bail Act 1977 (Vic), ss 1B, 3AAA, 4AA, 4A, 4D, 4E, 5AAA, Schedule 1, Item 6(a), (b).

Re Miftari [2025] VSC 843 (Opens in a new tab/window)

Tinney J
24 December 2025
Catchwords

CRIMINAL LAW - Bail - Murder - Allegation that the applicant was one of two men who lay in wait for victim, then shot him dead with the use of a shotgun and another weapon - Possible organised crime connection - Victim feared attack, and was armed with a handgun for self-defence - Victim fired shots in course of attack upon him - Applicant and co-offender driven to hospital with gunshot wounds following altercation - DNA linking both alleged offenders to scene of shooting - Strength of prosecution case - Applicant aged 21 with no criminal history - Sustained serious injuries in incident - Question as to the sufficiency of medical treatment provided to applicant in custody - Psychological condition of applicant - Onerous conditions in custody, including very limited time out of cell each day - Likely to be ongoing - Family support - Substantial bail guarantee offered - Delay - Question of risk - Use of police intelligence as informing issue of risk - Exceptional circumstances not established - Unacceptable risk in any event - Bail refused - Bail Act 1977 ss 1B, 3AAA, 4, 4A, 4AA, 4D, 4E, 8.

Criminal law

DPP (Cth) v Al Salman [2024] VSC 619 (Opens in a new tab/window)

Champion J
08 October 2024
Catchwords

CRIMINAL LAW - Ruling One - Charges of aggravated servitude - Evidence of past conduct occurring interstate - Application to exclude evidence pursuant to s 137 refused - Evidence Act 2008.

R v Dalton & Ors [2025] VSC 826 (Opens in a new tab/window)

Gorton J
19 December 2025
Catchwords

CRIMINAL LAW - Manslaughter by unlawful and dangerous act - Statutory complicity - Where three offenders entered agreement to dangerously assault and rob deceased - Exact cause of death not known - Attempted dismemberment and disposal of body - Attempted destruction of evidence by housefire - Each offender to be sentenced on different factual bases - Where first co-offender is sentenced on basis she was present but did not physically participate in assault - Markedly deprived childhood - No history of violent criminal behaviour and reasonable prospects of rehabilitation - Where second co-offender is sentenced on basis that he inflicted prolonged assault involving hog-tying and choking deceased and use of weapons, attempted to dismember body, transported body in a wheelie bin and disposed of body near train tracks and kept finger as a trophy - Second co-offender set fire to house in attempt to destroy evidence - No remorse in period following offending - Relevant criminal history and 'guarded' prospects of rehabilitation - Possibility of deportation - Where Verdins and Bugmy principles enlivened for first and second co-offenders - Pleas of guilty avoided need for separate trials - Where third co-offender is sentenced on basis that he was not present during the assault that led to death but encouraged violence and provided logistical support - Third co-offender found guilty after trial - Limited remorse and acceptance of responsibility - Limited prior criminal history and good to reasonable prospects of rehabilitation - First co-offender sentenced to seven years' imprisonment with non-parole period of five years - Second co-offender sentenced to 12 years' imprisonment with non-parole period of eight years and six months - Third co-offender sentenced to 10 years' imprisonment with non-parole period of six years - R v Verdins (2007) 16 VR 269 - Guden v The Queen (2010) 28 VR 288 - Ulutui v The Queen [2012] VSCA 301 - Bugmy v The Queen (2013) 249 CLR 571 - Contos v The Queen [2022] NSWCCA 92 - R v Bos [2023] VSC 68.

Secretary to the Department of Justice and Community Safety v Walkley (No 2) [2025] VSC 821 (Opens in a new tab/window)

Beach JA
19 December 2025
Catchwords

CRIMINAL LAW - Serious violent offender - Serious sex offender - Supervision orders - Unacceptable risk - Degree of risk that offender will reoffend - Consequences if risk eventuates - Offender assessed as 'low risk' of sex offending - Offender assessed variously as 'moderate risk' and 'low-to-moderate risk' of serious violence offending - Whether cogent evidence to a high degree of probability that offender still poses an unacceptable risk - Serious Offenders Act 2018, ss 14, 99, 104, 105 and 106.

County Court of Victoria

Joinder of further defendants, pleadings

Zhang v Wealth for Life Institute [2025] VCC 1794 (Opens in a new tab/window)

Judge Tsikaris
19 December 2025
Catchwords

JOINDER OF FURTHER DEFENDANTS, PLEADINGS - Application for review under r84.03(3) of the County Court Civil Procedure Rules 2008 - Whether there should be joinder of further defendants - Proposed defendants are employees of the first defendant acting in the course of their employment and within the scope of their employment - Exemplary damages - Pleadings.

Contract

Leon Cycle Pty Ltd v Hi5 Scooters Pty Ltd & Raad [2025] VCC 1914 (Opens in a new tab/window)

Judge Burchell
19 December 2025
Catchwords

CONTRACT - FRANCHISES - Whether the first defendant breached a licensing agreement - Whether the first defendant failed to report sales as required - Whether the first defendant failed to pay proceeds of sales - Whether the first defendant failed to return goods to the plaintiff - Whether the second defendant is personally liable for damages for breach - Whether the first defendant holds proceeds of sale on trust for the plaintiff - Terms of the licensing agreement - Whether the plaintiff was entitled to terminate - Whether the plaintiff suffered loss and damage - Whether the Franchising Code applies - Whether the plaintiff breached the Franchising Code - Whether the plaintiff breached the licensing agreement - Whether the second defendant is entitled to an indemnity.

Equity

Leda Constructions v 22 Upton Rd [2025] VCC 1112 (Opens in a new tab/window)

Judge Marks
19 December 2025
Catchwords

EQUITY - EQUITABLE REMEDIES - INJUNCTION - INTERIM INJUNCTION - SERIOUS QUESTION TO BE TRIED - BALANCE OF CONVENIENCE GENERALLY - Whether the first defendant should be restrained from calling on three bank guarantees provided by the plaintiff as performance bonds under a building contract - The bank guarantees perform both security and risk allocation functions under the contract - Synergy Construct Australia Pty Ltd v GSA North Terrace Pty Ltd [2025] SASCA 72 - Sugar Australia Pty Ltd v Lend Lease Services Pty Ltd [2015] VSCA 98 - Fletcher Construction Australia Ltd v Varnsdorf Pty Ltd [1998] 3 VR 812.

Summary judgment

Commonwealth Bank of Australia v Cahill & Anor [2025] VCC 1860 (Opens in a new tab/window)

Judge Wise
15 December 2025
Catchwords

SUMMARY JUDGMENT - Mortgages - Recovery of possession - Default under home loan - Failure to remedy arrears - Service of notice under s 76 Transfer of Land Act - Validity and enforceability of mortgage - Allegations of invalid loan contract - Memorandum of common provisions - Demand for "wet-ink" documents - Securitisation arguments - Counterclaim - Law Reform - Effectiveness of Civil Procedure Act 2010 in achieving its objectives - Particularly in relation to self-represented litigants.

Magistrates' Court of Victoria

Criminal law

Rabb & Fiddes v Tayeh [2025] VMC 17 (Opens in a new tab/window)

Magistrate MH Thomas
18 December 2024
Catchwords

CRIMINAL LAW - Insulting words - s 17 Summary Offences Act - Freedom of expression - s 15 Charter of Human Rights and Responsibilities Act - Implied freedom of political communication.

Legislation

Articles

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