Library Bulletin

From the Director

Victorian Court of Appeal

Torts

Smit v State of Victoria [2026] VSCA 106 (Opens in a new tab/window)

Beach and Richards and Whelan JJA
19 May 2026
Catchwords

TORTS - False imprisonment - Applicant arrested three times during protest gathering - Applicant claimed all three arrests unlawful - First and third arrests held unlawful, second arrest found to be lawful - Proposed appeal raised new arguments in respect of lawfulness of second arrest - Whether arguments could have been met by evidence or submission at trial - Whether in the interests of justice to permit arguments to be raised for the first time on appeal - Whether judge correct to find, in respect of second arrest, there existed a belief on reasonable grounds that an offence was being committed.

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.

Wills and estates

Milekovic v Vrantsidis [No 2] [2026] VSCA 102 (Opens in a new tab/window)

Walker JA
21 May 2026
Catchwords

WILLS AND ESTATES - Application for leave to appeal - Applicant and first respondent were beneficiaries of their father's estate - Will appointed applicant executor - Will required non-monetary assets be called in and converted into money - Applicant proposed to transfer late father's house into her and first respondent's names jointly - First respondent commenced proceedings for sale of property and removal of executor - Parties entered deed of settlement - Property sold pursuant to settlement deed but $100,000 remained in trust - Trial judge removed applicant as executor and made consequential orders - Applicant alleged judge was affected by bias and failed to take into account evidence - Application totally without merit - Leave to appeal refused.

Courts

HM (a pseudonym) v Sister Monaghan [2026] VSCA 104 (Opens in a new tab/window)

Niall CJ and Beach JA and O'Meara AJA
21 May 2026
Catchwords

COURTS - Abuse of process - Application for permanent stay of child abuse proceeding - Historical child sexual abuse allegations - Application for permanent stay on grounds of prejudice by reason of loss of evidence due to passage of time - Plaintiff unable to identify alleged perpetrators - Whether inability to identify perpetrators an exceptional circumstance justifying stay - Relevance of institutional setting - Whether defendant has access to sufficient evidentiary material to defend action - Associate judge refused permanent stay - Leave granted for appeal to be considered by Court of Appeal - Appeal dismissed.

Practice and procedure

Create Environment Pty Ltd v Renex Founder Hold Co Pty Ltd [2026] VSCA 103 (Opens in a new tab/window)

Lyons and Kenny JJA and J Forrest AJA
20 May 2026
Catchwords

PRACTICE AND PROCEDURE - Pleadings - Oppression proceeding - Where plaintiff sought to raise new issue affecting share valuation and/or adjustment if oppression established - No application made to amend - Defendant objected - Judge ruled new issue relevant on ground of credit but indicated any other use would need to be established by further submissions - Plaintiff relied upon new issue in final submissions as relevant to significant adjustment to buy-out price - Defendant objected based on pleadings and that further evidence would have been called if new issue raised in timely way - Judge exercised discretion to limit use of evidence on new issue to credit as otherwise unfairly prejudicial to defendant - In doing so judge exercised powers under Evidence Act 2008, s 136 - No error - Leave to appeal refused.

Cwalina v Rose [No 3] [2026] VSCA 105 (Opens in a new tab/window)

Walker JA
21 May 2026
Catchwords

PRACTICE AND PROCEDURE - Appeal - Application for stay and related orders pending determination of special leave application - Applicants' submissions directed to allegations concerning their liability (or lack of liability) for first respondent's costs - No substantial prospect that special leave to appeal will be granted - Application refused.

Milekovic v Vrantsidis & Anor [No 1] [2026] VSCA 100 (Opens in a new tab/window)

Walker JA
15 May 2026
Catchwords

PRACTICE AND PROCEDURE - Application for leave to appeal against interlocutory decision - Applicant was defendant below in a wills and estates proceeding - First respondent objected to competency and timing of application to this Court - Applicant sought orders pursuant to s 29 of the Civil Procedure Act 2010 for compensation and summary dismissal of proceeding - Court allowed respondent (who was plaintiff below) to amend originating motion - Court postponed determination of s 29 application until proceeding finally determined - Underlying proceeding and s 29 application later dismissed and applicant made separate application for leave to appeal in relation to final decision - Present application would serve no useful purpose - Application totally without merit - Leave to appeal refused.

Criminal law

Agresta v The King [2026] VSCA 101 (Opens in a new tab/window)

Emerton P and Beach JA
19 May 2026
Catchwords

CRIMINAL LAW - Sentence - Appeal - Application for extension of time within which to seek leave to appeal - Application to adduce fresh evidence - Substantial sentences imposed on applicant for serious drug offending - Applicant released on bail pending hearing of applications for leave to appeal against conviction and sentences based on fresh evidence that Lawyer X was an undisclosed police source - Applications for leave to appeal against conviction and sentence subsequently abandoned, and applicant returned to custody to serve balance of sentences - Whether circumstances relied upon by applicant constitute fresh evidence reopening sentencing discretion - Evidence relied on by applicant not demonstrating true significance of facts existing at time of sentence - Application for leave to appeal not reasonably arguable - Futile to grant extension of time application - Application for extension of time within which to seek leave to appeal refused.

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.

Ballard (a pseudonym) v The King [2026] VSCA 110 (Opens in a new tab/window)

Beach and Taylor and Donaghue JJA
26 May 2026
Catchwords

CRIMINAL LAW - Conviction - Appeal - Rape - Evidence - Evidence of historical injuries inflicted by applicant on complainant - Evidence admitted without objection - Whether admission of evidence resulted in substantial miscarriage of justice - Whether reliance on, or use of, evidence as tendency evidence resulted in substantial miscarriage of justice - No objection by defence counsel to use of evidence as tendency evidence - Rational basis for not objecting to admission of evidence to use as tendency evidence - Proposed appeal against conviction not reasonably arguable - Application for leave to appeal against conviction refused.

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.

DPP v Lin [2026] VSCA 109 (Opens in a new tab/window)

Taylor and Kidd JJA and Jane Dixon AJA
27 May 2026
Catchwords

CRIMINAL LAW - Appeal - Sentence - Crown appeal - Two charges of manslaughter by unlawful and dangerous act - Guilty plea - Respondent killed two sex workers within space of 24 hours - Total effective sentence of 14 years with non-parole period of 9 years - Whether sentence manifestly inadequate - Whether Court should exercise residual discretion to dismiss appeal - Sentence manifestly inadequate - Appeal allowed - Respondent resentenced to total effective sentence of 18 years with non-parole period of 14 years.

Eam v The King [2026] VSCA 108 (Opens in a new tab/window)

Boyce JA
22 May 2026
Catchwords

APPLICATION FOR LEAVE TO APPEAL AGAINST SENTENCE DETERMINED BY A SINGLE JUDGE PURSUANT TO S 315 OF THE CRIMINAL PROCEDURE ACT 2009.

El-Rajab v The King [2026] VSCA 107 (Opens in a new tab/window)

Walker and Donaghue JJA and Fox AJA
22 May 2026
Catchwords

CRIMINAL LAW - Sentence - Application for leave to appeal - Apprehended bias - Applicant pleaded guilty to attempting to pervert the course of justice and persistently breaching a family violence intervention order ('FVIO') - Total effective sentence of 1 year, 8 months' imprisonment with a non-parole period of 10 months - Sentencing judge had prosecuted applicant for unrelated serious offences in 2014 but did not recall this at the time of sentence - Whether judge's previous role as prosecutor gave rise to apprehended bias - Not necessary to form a view on grounds of appeal because applicant did not satisfy Court that a lesser sentence should be imposed - Leave to appeal granted - Appeal dismissed.

Ford v The King [2026] VSCA 89 (Opens in a new tab/window)

Taylor and Osborn JJA
18 May 2026
Catchwords

CRIMINAL LAW - Sentence - Dangerous driving causing serious injury - Driving vehicle whilst exceeding the prescribed concentration of drugs in blood - Applicant travelling in excess of speed limit distracted by mobile phone - Utility vehicle hit and seriously injured victim - Plea of guilty - Genuine remorse - Excellent prospects of rehabilitation - Whether sentence of four months' imprisonment with a two year Community Corrections Order manifestly excessive - No manifest excess given need for general deterrence and denunciation - Leave to appeal refused.

Frendo v The King [2026] VSCA 112 (Opens in a new tab/window)

Emerton P and T Forrest JA
27 May 2026
Catchwords

CRIMINAL LAW - Conviction - Application for leave to bring second appeal - Sexual penetration of child under 16 - Indecent act with child under 16 - Leave to appeal conviction refused on first appeal - New evidence - Whether evidence fresh and compelling - Evidence not fresh and compelling - Application for extension of time to bring second appeal refused.

Goussis v The King [2026] VSCA 75 (Opens in a new tab/window)

McCann JR
28 April 2026
Catchwords

CRIMINAL LAW - Application for leave to appeal against conviction - Applicant seeks documents from Chief Commissioner of Victoria Police - Application pursuant to s 317 of the Criminal Procedure Act 2009 - Where the respondent to production application submits that there is no legitimate forensic purpose - Where the respondent to production application submits the application amounts to a fishing expedition - Where the applicant has identified limited forensic purpose.

Grayson (a pseudonym) v The King [2026] VSCA 111 (Opens in a new tab/window)

Taylor and Kidd JJA and Jane Dixon AJA
27 May 2026
Catchwords

CRIMINAL LAW - Appeal - Application for leave to appeal - Applicant convicted of sexual offending against 14 year old step-daughter - Messages between applicant and step-daughter used to prove element of certain charges and as evidence of sexual interest - Messages refer to 'ur video' - Step-daughter denied knowledge of video - Whether prosecutor alleged uncharged act in address - Whether evidence of applicant masturbating in common areas admissible as tendency evidence - Application for leave to appeal refused.

Kon v The King [2026] VSCA 92 (Opens in a new tab/window)

Emerton P and Osborn JA
21 May 2026
Catchwords

CRIMINAL LAW - Sentence - Application to renew application for leave to appeal following refusal by single judge - Applicant and co-offender pleaded guilty to offences including conduct endangering persons, theft and discharge firearm at a vehicle with reckless disregard for safety - Charges arose out of high speed car chase in which offenders pursued and fired shots at another car - Applicant and co-offender both on bail at time of offending - Applicant sentenced to 5 years and 2 months' imprisonment with a non-parole period of 3 years and 6 months - Whether double punishment - Whether sentencing judge erred in taking into account as aggravating factor that offences committed on bail while also imposing wholly cumulative sentence for offence of committing indictable offence whilst on bail - Parity - Whether sentencing judge erred by failing to distinguish between applicant and co-offender's moral culpability in respective sentences on the conduct endangering persons charge - Leave to appeal refused.

SS v The King [2026] VSCA 113 (Opens in a new tab/window)

Beach and Boyce JJA and Elliott AJA
27 May 2026
Catchwords

CRIMINAL LAW - Appeal - Bail application refused - 17-year-old child - Appellant charged with aggravated home invasion - Schedule 1 offence - Standard of appellate review in relation to bail decisions - House v The King error must be shown - Unacceptable risk - Whether judge erred in assessment of Youth Justice supervised bail - Error established - Re-exercising discretion - Exceptional circumstances demonstrated - Appellant not an unacceptable risk if subject to strict conditions - Appeal allowed - Bail granted subject to conditions and bail monitoring.

Supreme Court of Victoria Commercial Court

Judgment

Yimiao Australia v 3V Development [No 2] [2026] VSC 295 (Opens in a new tab/window)

Attiwill J
19 May 2026
Catchwords

JUDGMENT - Whether plaintiff required to elect between remedies - Alternative and inconsistent remedies - Plaintiff required to elect - Ikosidekas v Glenis [2023] VSCA 134 - Port of Melbourne Authority v Anshun Pty Ltd (1981) 147 CLR 589 applied.

Group proceedings

Wong v Harvey Norman Holdings Ltd [2026] VSC 293 (Opens in a new tab/window)

Harris J
20 May 2026
Catchwords

GROUP PROCEEDINGS - Costs - Application for a group costs order - Whether necessary or appropriate to make order - Appropriate percentage rate for order - Relevant considerations - Supreme Court Act 1986 (Vic), s 33ZDA.

Corporations

Re Project Collaboration Pty Ltd (deregistered) [2026] VSC 284 (Opens in a new tab/window)

Gobbo AsJ
18 May 2026
Catchwords

CORPORATIONS - Insolvency - Application for investigation into liquidation - Review of liquidator's conduct - No basis for complaints - No jurisdiction to order an inquiry - Not an appropriate case for an inquiry - Plaintiff seeking to vindicate private rights - Investigation not in the public interest - Corporations Act 2001 (Cth), ss 533, 545, sch 2, ss 90-10, 90-15, 90-20 - Australian Securities and Investments Commission v Wily [2019] NSWSC 521 - Jenkins v Jonkay [2007] FCA 858 - Djordjevich v Rohrt [2021] VSC 178 - Djordjevich v Rohrt (2022) 67 VR 161 - Application refused.

Re Timbercorp Securities Ltd (in liq) [2026] VSC 287 (Opens in a new tab/window)

Gobbo AsJ
18 May 2026
Catchwords

CORPORATIONS - Winding up - Conduct of liquidation - Application for directions - Distribution of assets - Application for judicial advice - Corporations Act 2001 (Cth), sch 2, s 90-15 - Rule 54.02 Supreme Court (General Civil Procedure) Rules 2025 (Vic) - Court's exercise of discretion in relation to contemplated conduct - Appropriate to give directions and advice.

Misleading and deceptive conduct

Plan B Properties Pty Ltd v Australian Secured & Managed Mortgages Pty Ltd & Ors [2026] VSC 306 (Opens in a new tab/window)

M Osborne J
22 May 2026
Catchwords

MISLEADING AND DECEPTIVE CONDUCT - Where plaintiff was a private investor participating in a syndicated mortgage lending arrangement - Where mortgage broker arranged short-term property development loan secured by first registered mortgage over property - Where loan participants advanced funds totalling $4.25 million, including $1.5 million contributed by plaintiff in reliance on valuation - Where key investment material prepared by registered valuer represented land as worth $10 million and characterised loan as 'low-risk' - Where borrower defaulted and property was sold following appointment of receivers - Where substantial shortfall suffered by plaintiff - Whether valuer prepared a defective valuation - Whether representations made by mortgage broker and its officer were misleading or deceptive under the Australian Consumer Law (ACL) and related provisions - Damages recoverable against valuer for negligent valuation - Claim against mortgage broker and second defendant dismissed.

Contract

Mould v GW & R Mould Pty Ltd (No 2) [2026] VSC 291 (Opens in a new tab/window)

Connock J
19 May 2026
Catchwords

CONTRACT - Alleged loan agreement and mortgages - Alleged failure to pay loan advance and interest - Alleged sham agreement between the parties - Alleged common intention that loan agreement not be binding - Loan rollovers and refinancing - Whether loan documents reflected parties' agreement - Sham agreements - General principles - Solicitor's certificates - Borrower's declarations and acknowledgements.

Trusts

Jensen Reid Pty Ltd & Anor v The Specialist Property Group Pty Ltd [2026] VSC 301 (Opens in a new tab/window)

Nichols J
21 May 2026
Catchwords

TRUSTS - Removal and replacement of trustee - Voluntary retirement of outgoing trustee - Court to appoint incoming trustee pursuant to s 48 of the Trustee Act 1958 (Vic) - Where plaintiffs propose trustee company owned and directed by beneficiaries - Where defendant proposes independent professional trustee - Insufficient evidence to prove defendant's proposed trustee is independent or can administer the trust - Plaintiffs' proposed trustee appointed.

Insurance

Danbol Pty Ltd v ACN 007 198 343 Pty Ltd [2026] VSC 305 (Opens in a new tab/window)

M Osborne J
22 May 2026
Catchwords

INSURANCE - Property insurance - Insurance agents and brokers - Claims generally - Property damage caused by fire - Negligence - Causation - Counterfactuals and hypothetical analysis - Admitted negligence - Whether broker's negligence caused the loss - Failure to accept offer of insurance - Failure to advise - Whether hypothetical insurer would have been liable to indemnify - Onus of proof in establishing loss - Whether there was a change in use - Act of some other person - Whether third party tenant constituted some other person - Whether relevant act was failure to notify - Change in tenancy - Timing of change in use - By reason of act after contract entered into - Commencement date of policy - Whether insurance policy which plaintiff would have obtained but for the breach of duty would have responded to a claim for damage to property by fire - Insurance Contracts Act 1984 (Cth) ss 54, 55, 60 - Wrongs Act 1958 (Vic) s 52 - Flanagan v Bernasconi [2023] NSWCA 150 - Strong v Woolworths [2012] HCA 5 - Gibbs Holdings Pty Ltd v Mercantile Mutual Insurance (Australia) Ltd [2002] 1 Qd R 17 - Ferrcom Pty Ltd v Commercial Union Assurance Co of Australia Pty Ltd (1993) 176 CLR 332 - Swiss Re International Se v LCA Marrickville Pty Ltd [2021] FCA 1206 - Antico v Heath Fielding Australia Pty Ltd (1997) 188 CLR 652 - Hypothetical insurer liable to indemnify.

Glass Recovery Services Pty Ltd (recs and mgrs apptd) (in liq) v Certain Underwriters at Lloyd's [2026] VSC 314 (Opens in a new tab/window)

Matthews J
28 May 2026
Catchwords

INSURANCE - Industrial special risks and consequential loss of profits policy - Property loss and damage - Whether removal and disposal of stock by government authority during a clean-up of premises is 'confiscation' - Whether property loss and damage is excluded by operation of exclusion clauses and endorsements in insurance policy.

Costs

Country Club Villages Pty Ltd & Ors v Burke & Ors (No 2) [2026] VSC 300 (Opens in a new tab/window)

Craig J
20 May 2026
Catchwords

COSTS - Whether indemnity costs should be ordered after the rejection of a suite of Calderbank offers - Whether indemnity costs should be granted following the rejection of an open offer made in respect of claims concerning one of three disputed properties - Costs ordered on an indemnity basis in respect of the claims concerning one of the disputed properties following the rejection of the open offer - Supreme Court Act 1986 (Vic) s 24(1) - Supreme Court (General Civil Procedure) Rules 2025 (Vic) r 63.31 - Calderbank v Calderbank [1976] Fam 93; [1975] 3 All ER 333 applied; Hazeldene's Chicken Farm Pty Ltd v Victorian WorkCover Authority (No 2); (2005) 13 VR 435; [2005] VSCA 298 applied.

Karam Investments Pty Ltd v Close the Loop (No 2) [2026] VSC 318 (Opens in a new tab/window)

Croft J
26 May 2026
Catchwords

COSTS - Costs follow the event - Jurisdiction of Court to award costs where finding of lack of jurisdiction - Vexatious conduct of proceeding unnecessarily disadvantaging other party - Standard costs awarded (referable to powers applying in both the Court and VCAT) - Chen v Chan [2009] VSCA 233 - In re Crittendon; Ex parte The Law Institute of Victoria [1958] VR 101 - Kinex Exploration Pty Ltd v Tasco Pty Ltd [1995] 2 VR 318 - Cabot v City of Keilor [1994] 1 VR 220 - State of Victoria v Bradto Pty Ltd (Palace Entertainment Complex) and Tymbook Pty Ltd [2006] VCAT 1813 - Supreme Court Act 1986 s 24 - Retail Leases Act 2003 s 92 - Victorian Civil and Administrative Tribunal Act 1998 s 109 - Civil Procedure Act 2010 Part 2.3.

Appeals

Bridgewater Poultry Farm Pty Ltd v Ash & Sons Eggs Pty Ltd [2026] VSC 286 (Opens in a new tab/window)

Attiwill J
19 May 2026
Catchwords

APPEALS - INTERSTATE SERVICE OF INITIATING PROCESS - Appeal from a decision of a Judicial Registrar dismissing the defendants' application concerning alleged deficiency in interstate service of a writ - Whether service of writ effected on defendants in accordance with s 16 of the Service and Execution of Process Act 1992 (Cth) - Document attached to writ did not strictly comply with form of notice prescribed by r 6 of the Service and Execution of Process Regulations 2018 (Cth) - Held service was ineffective as document attached to writ did not substantially comply with prescribed form - Appeal allowed - Energy Conservation Systems Pty Ltd v Downer EDI Engineering Electrical Pty Ltd (2008) 221 FLR 393, Carron Investments Pty Ltd v Lang [2016] VSCA 287 and MZAIC v Minister for Immigration and Border Protection (2016) 237 FCR 156, applied - Adams v Lambert (2006) 228 CLR 409, distinguished.

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.

Commonwealth Bank of Australia v Qiu [2026] VSC 315 (Opens in a new tab/window)

Fary AsJ
25 May 2026
Catchwords

PRACTICE AND PROCEDURE - Summary judgment - Plaintiff seeks summary judgment against defendants - Civil Procedure Act 2010 (Vic), ss 61, 63 - Where grounds of defence hold no real prospects of success - No other defence apparent on the materials - Lysaght Building Solutions Pty Ltd v Blanalko Pty Ltd (2013) 42 VR 27, applied - Summary judgment, granted.

Façade Designs International Pty Ltd v Yuanda Vic Pty Ltd (No 3) [2026] VSC 316 (Opens in a new tab/window)

Cosgrave J
25 May 2026
Catchwords

PRACTICE AND PROCEDURE - Reference of all questions in the dispute to a special referee - Supreme Court (General Civil Procedure) Rules 2025 (Vic) Order 50 - Whether Court should adopt special referee's report under r 50.04 - Report adopted.

Façade Designs International Pty Ltd v Yuanda Vic Pty Ltd (No 4) [2026] VSC 328 (Opens in a new tab/window)

Cosgrave J
27 May 2026
Catchwords

PRACTICE AND PROCEDURE - Security for costs - Application by plaintiff for release from obligation to provide security - Where plaintiff has succeeded in the proceeding - Application granted.

Hanjun Bi v Dongge Qin & Ors [2026] VSC 322 (Opens in a new tab/window)

Craig J
25 May 2026
Catchwords

PRACTICE AND PROCEDURE - Application for summary judgment pursuant to s 63 Civil Procedure Act 2010 (Vic) - Allegations of existence and breach of joint venture agreement - Defendants did not establish no real prospect of success - Alternative application to strike out the amended statement of claim - Pleading struck out in part - Leave to replead granted.

Supreme Court of Victoria Common Law Division

Practice and procedure

White v Poynton [2026] VSC 311 (Opens in a new tab/window)

Gray J
25 May 2026
Catchwords

PRACTICE AND PROCEDURE - Statutory Will - Court authorised wills - Application by daughter - Application opposed by professional administrator - Whether plaintiff entitled to production of documents or discovery - Whether documents relate to question in proceeding - Proceeding by originating motion - Whether special circumstances exist - Inquisitorial role - Wills Act 1997 pt 1 div 2 - Supreme Court (General Civil Procedure) Rules 2025 rr 29.07(2)-(3), 29.08 - Civil Procedure Act 2010 ss 7, 8, 9 - Reed v Reed [2001] VSC 54 - Blair v Blair [2002] VSC 131 - Harris v Bennett (No 3) (2004) VR 425 - Grege v Grege [2024] VSC 475.

Administration and probate

Re Rodgers [2026] VSC 317 (Opens in a new tab/window)

Moore J
27 May 2026
Catchwords

ADMINISTRATION AND PROBATE - Letters of administration - Presumption of death - Where person missing for 36 years - Where all due enquiries made to locate missing person - No evidence to suggest missing person is alive - Axon v Axon (1937) 59 CLR 395 - Chard v Chard [1956] P 259 - Administration and Probate Act 1958 (Vic) s 7.

Contract

Papanastassis v Papanastassis [2026] VSC 302 (Opens in a new tab/window)

Irving AsJ
21 May 2026
Catchwords

CONTRACT - Settlement - Whether binding agreement to settle made by sending unsigned deed via email - Where plaintiffs executed draft deed - Where parties reached in-principle agreement at mediation - Where defendants resiled from deed after provision to plaintiffs - Reasonable observer would have concluded that parties intended to be bound by sending unsigned deed via email - Masters v Cameron (1954) 91 CLR 353 and Sully v Englisch [2022] VSCA 184 applied - Pavlovic v Universal Music Australia Pty Ltd (2015) 90 NSWLR 605 distinguished.

Common law

Ofli v State of Victoria [2026] VSC 289 (Opens in a new tab/window)

McCann JR
19 May 2026
Catchwords

COMMON LAW - Application for summary dismissal - Application for strike out of pleadings in the alternative - Supreme Court (General Civil Procedure) Rules 2025 (Vic) - Whether the claim is unmeritorious - Whether the plaintiff ought to be afforded a further opportunity to re-plead its claim - Self-represented litigant.

Compulsory acquisition

Minister for Health v Pakenham Place Shopping Centre JV Pty Ltd [2026] VSC 326 (Opens in a new tab/window)

Quigley J
29 April 2026
Catchwords

COMPULSORY ACQUISITION - Practice and procedure - Application for summary judgment - Where it is alleged that claims do not have any real prospect of success - Where it is alleged that claims are scandalous, frivolous, vexatious or an abuse of the process of the Court - High bar for establishing a claim for summary judgment - Appropriateness of recourse to summary judgment in compulsory land acquisition proceedings - Deficient pleadings can be rectified by timetabling orders - Summary judgment application dismissed - No order as to costs on the summary dismissal application - Costs of the directions hearing reserved.

Personal injuries

McCann v Phillips [2026] VSC 325 (Opens in a new tab/window)

O'Meara J
25 May 2026
Catchwords

PERSONAL INJURIES - Trial practice - Leave reserved to the defendant to move non obstante veredicto - Verdict of a civil jury - Whether no evidence upon which a reasonable jury, properly directed, could have returned a verdict for the plaintiff - Jury verdict plainly explicable with reference to the evidence received at trial - King v Amaca Pty Ltd [2011] VSC 422 considered and applied - Application dismissed.

Bias

Lamont v The Royal Women's Hospital & Anor (No 1) [2026] VSC 310 (Opens in a new tab/window)

K Judd J
22 May 2026
Catchwords

BIAS - Whether judge biased - Apprehended bias - Recusal application refused.

Administrative law

Khan v Longmire [2026] VSC 309 (Opens in a new tab/window)

Quigley J
22 May 2026
Catchwords

ADMINISTRATIVE LAW - Appeal from Victorian Civil and Administrative Tribunal against costs orders - Oral reasons - Subsequent request for written reasons - Whether Tribunal used correct legal test to determine costs - Whether there was any evidence to support factual finding - Whether finding that the case had been 'made more complex' satisfied the statutory criteria to award costs - Adequacy of reasons - Whether use by Tribunal of AI-generated transcript demonstrated error - Relevance of oral reasons after written reasons - Whether appeal on costs needs to demonstrate exceptionality - Leave to appeal on novel ground - Appeal dismissed.

Syan v Rowe [2026] VSC 323 (Opens in a new tab/window)

Hay J
28 May 2026
Catchwords

ADMINISTRATIVE LAW - Judicial review - Workplace injury - Opinion of Medical Panel - Adequacy of Medical Panel's reasons - Relief refused - Devaney v Crown Melbourne Ltd [2021] VSCA 168, Wingfoot Australia Partners v Kocak (2013) 252 CLR 480, Richter v Driscoll (2016) 51 VR 95, A & L Windows Pty Ltd v Yildirim [2022] VSCA 46, Sidiqi v Kotsios [2021] VSCA 187, Vangelovski v Calco Timbers Pty Ltd [2022] VSC 508 - Workplace Injury Rehabilitation and Compensation Act 2013 (Vic), ss 274, 304(a), 304(b), 313(4), 313(3).

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

Diakou v Victorian Legal Services Board [2026] VSC 304 (Opens in a new tab/window)

Keogh J
21 May 2026
Catchwords

APPEAL - Appeal from order of the Victorian Civil and Administrative Tribunal refusing application for stay - Refusal to renew solicitor's practicing certificate - Whether Senior Member erred in dismissing stay application - Jurisdictional error - Unreasonableness - Identification of public interest - Victorian Civil and Administrative Tribunal Act 1998 s 50(3) - Legal Profession Uniform Law Application Act 2014 s 45 - Leave to appeal allowed - Application refused.

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.

Judicial review

Chen v Victorian Legal Services Commissioner [2026] VSC 320 (Opens in a new tab/window)

Watson J
28 May 2026
Catchwords

JUDICIAL REVIEW - Application for leave to appeal the Victorian Civil and Administrative Tribunal costs order - Applicant applied for costs following withdrawal of disciplinary proceedings - Costs could only be awarded against Victorian Legal Services Commissioner if 'special circumstances' existed - Whether the Tribunal erred in finding no 'special circumstances' existed to justify a costs order - Whether the Tribunal denied procedural fairness - No merit in any of the grounds of the application for leave - Leave to appeal refused - Victorian Civil and Administrative Tribunal Act 1998 (Vic) cl 46D of sch 1.

Han v Victorian WorkCover Authority [2026] VSC 273 (Opens in a new tab/window)

Watson J
14 May 2026
Catchwords

JUDICIAL REVIEW - Application by a worker under s 328 of the Workplace Injury Rehabilitation and Compensation Act 2013 (Vic) to bring proceedings for damages for an injury - Where an injury is deemed to be a serious injury under s 335(1) - Whether Authority required to advise worker that injury was deemed to be a serious injury - Whether response provided pursuant to s 330(1)(a) amenable to judicial review - Response subject to judicial review - Authority required to advise that worker was deemed to have a serious injury - Gievski v Victorian WorkCover Authority [2017] VSC 598 distinguished.

Susman v Oakley Thompson & Co Pty Ltd [2026] VSC 298 (Opens in a new tab/window)

Ginnane J
20 May 2026
Catchwords

JUDICIAL REVIEW - Whether a Judge of the Supreme Court can grant judicial review remedies in respect of a Judicial Registrar's case transfer determination - Judicial Registrar was a judicial officer of the Court - Whether determination was judicial or administrative - Constitution Act 1975, s 75(2).

Civil procedure

Agnello v Heritage Care Pty Ltd (No 3) [2026] VSC 303 (Opens in a new tab/window)

Baker JR
20 May 2026
Catchwords

CIVIL PROCEDURE - Discovery - Appropriateness of general discovery or discovery by categories in a group proceeding - Interaction between statutory privacy obligations and principles of discovery - Restrictions on disclosure of protected information under the Aged Care Act 1997 (Cth) - Disclosure of group members' personal or medical information in connection with the initial trial of a group proceeding - Relevance to real issues in dispute defined by pleadings - Scope of categories narrowed by amending language and temporal ranges - Supreme Court (General Civil Procedure) Rules 2025 (Vic) rr 29.01.1, 29.05, 29.05.1, 29.07, and 29.08.

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.

Stuart v Department of Health [2026] VSC 319 (Opens in a new tab/window)

Baker JR
27 May 2026
Catchwords

CIVIL PROCEDURE - Application for summary judgement - Application to strike-out pleading - High threshold of 'no real prospect of success' - Self-represented plaintiff - Statement of claim drafted in an unclear manner - Material facts not stated - Elements of negligence not adequately addressed on the pleadings - Existence of a relevant duty of care undetermined - Fact-sensitive nature of distinguishing between government policy and operational conduct - Statement of claim struck out - Summary judgment application adjourned until plaintiff has repleaded - Civil Procedure Act 2010 (Vic) ss 62 and 63 - Supreme Court (General Civil Procedure) Rules 2025 r 23.02.

Supreme Court of Victoria Criminal Division

Bail

Oakroot v Victoria Police [2026] VSC 288 (Opens in a new tab/window)

Forbes J
15 May 2026
Catchwords

BAIL - Applicant for bail an Aboriginal person - Accused also subject to Treatment Order under the Mental Health and Wellbeing Act 2022 (Vic) - Compelling reasons test met - Risk not unacceptable while Inpatient Treatment Order in force - Bail granted - Bail Act 1977 (Vic) ss 3A, 4E.

Re Showler [2026] VSC 307 (Opens in a new tab/window)

Forbes J
20 May 2026
Catchwords

CRIMINAL LAW - APPLICATION FOR BAIL - Compelling reasons test under section (4AA)(4A) of the Bail Act 1977 - Opposed on the basis of an unacceptable risk of failing to surrender into custody in accordance with the bail undertaking - High risk of failing to answer to bail - Conditions cannot make risk acceptable - Bail refused - Bail Act 1977 (Vic) s 4AA(4A), s 4E(1)(a)(iv) - Re Boland [2024] VSC 85.

Criminal law

DPP v Telenta [2026] VSC 297 (Opens in a new tab/window)

Fox J
20 May 2026
Catchwords

CRIMINAL LAW - Sentencing - Manslaughter by criminal negligence - Offender accidentally injected her partner with heroin - Attempted to revive him by injecting him with methylamphetamine, which was his usual drug - Delayed calling an ambulance but ultimately called '000' - Performed CPR and remained at scene - Full and frank admissions to police - But for admissions, offender would not have been prosecuted - Guilty plea - Substantial mitigation - Mental health issues - Doran discount - Low level example of this type of manslaughter - Category 2 offence pursuant to the Sentencing Act - Section 5(2H) exceptions not established - Sentenced to 3 years' imprisonment, with a non-parole period of 15 months - Sentencing Act 1991 (Vic) ss 5(2H)(c)(ii), 5(2H)(e) - R v Doran [2005] VSCA 271; R v Verdins (2007) 16 VR 269; Peers v The Queen [2021] VSCA 264; DPP v Lombardo (2022) 302 A Crim R 329.

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) VSC 148; 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 [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.

Criminal appeal

D'Aloia v The King [2026] VSC 290 (Opens in a new tab/window)

McCann JR
18 May 2026
Catchwords

CRIMINAL APPEAL - Factual questions referred to the trial division for determination pursuant to s 319A of the Criminal Procedure Act 2009 (Vic) - Application for a pseudonym order - Where an individual is alleged to be a police informer - Open Courts Act 2013 (Vic) - Where there is a public interest in protecting police informers - Where Victoria Police are required to be seen to maintain confidence in ability to protect informers - Where public interest is sufficient to warrant the making of an order.

County Court of Victoria

Contract

Glen v Sherwood & Ors [2026] VCC 668 (Opens in a new tab/window)

Judge A Ryan
21 May 2026
Catchwords

CONTRACT - TRUSTS - CONSUMER LAW - CAVEATS - Joint venture to develop a metal detection system - Whether the parties entered into a binding oral contract - Effect of subsequent written memorandum of understanding - Breakdown of joint venture - Whether funds invested by the plaintiff in the joint venture subject to a remedial constructive trust or resulting trust - Alleged misleading and deceptive conduct regarding valuation of the joint venture - Counterclaim for removal of caveat lodged by the plaintiff over joint venture property.

Practice and procedure

Austin v State of Victoria (Ruling No 5) [2026] VCC 616 (Opens in a new tab/window)

Judge Pillay
21 May 2026
Catchwords

PRACTICE AND PROCEDURE - Application for leave to continue proceedings by a person subject to a general litigation restraint order under the Vexatious Proceedings Act 2014 - Vexatious proceeding - Abuse of process.

Lewis (a pseudonym) v Lewis (a pseudonym) [2026] VCC 612 (Opens in a new tab/window)

Judge Pillay
20 May 2026
Catchwords

PRACTICE AND PROCEDURE - Application for leave to continue proceedings - Whether proposed proceeding is vexatious - Whether there are reasonable grounds for proposed proceeding.

Robertson and Ors v Melbourne Health (Ruling) [2026] VCC 627 (Opens in a new tab/window)

Judge K L Bourke
15 May 2026
Catchwords

PRACTICE AND PROCEDURE - Application by plaintiffs seeking review pursuant to r 84.03(3) of the County Court Civil Procedure Rules 2018 (Vic) of decision of the Court constituted by judicial registrar dismissing plaintiffs' applications.

Legislation

Articles

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