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National Court of Papua New Guinea |
PAPUA NEW GUINEA
[IN THE NATIONAL COURT OF JUSTICE]
OS NO. 750 OF 2005
IN THE MATTER OF AN APPLICATION
BY TIMOTHY MATHEW O’DWYER trading as
O’DWYER & BRADLEY SOLICITORS
of Brisbane, Australia
Plaintiff
AND:
ARNOLD THEODORUS DERKS
Defendant
Lae: Manuhu, J
2007: March 3 & June 14
RULING
JUDGMENT – Reciprocal enforcement – Setting aside – Grounds – Natural justice – Insufficient notice – Public policy – Equitable fraud.
EVIDENCE – Reciprocal enforcement – Setting aside – Fraud – Standard of proof.
WORDS AND PHRASES – Fraud – Equitable fraud – Definitions – Distinctions.
Cases cited in the judgment:
Papua New Guinea cases
Overseas Cases:
Counsel:
P. Ousi, for the Plaintiff. J. Bray, for the Defendant.
14 June, 2007
1. MANUHU, J.: Introduction: This is an application by Arnold Theodorus Derks (Derks) pursuant to section 5 (1) of the Reciprocal Enforcement of Judgments Act (Act) to set aside the registration of a foreign judgment obtained against him in Queensland by Timothy Mathew O’Dwyer (O’Dwyer).
2. Derks also seeks consequential orders that O’Dwyer, by his lawyers Warner Shand Lawyers, of Lae, provide to his lawyers copies of all documents relied on by O’Dwyer to authorise his service on Derks (while in Papua New Guinea) of all filed documents, orders or judgement issuing out of the Queensland Supreme Court.
Background
3. Derks, a permanent resident of Lae, was the Defendant in proceedings commenced in the Supreme Court of Queensland (Statement of Claim No. 2480 of 2005, filed on 29 March 2005). O’Dwyer’s claim was for legal services (costs and outlays) rendered to Derks for work done when O’Dwyer acted for Derks in a matrimonial proceeding. Derks did not file a notice of intention to defend and defence in the Queensland Supreme Court proceeding. On 9 May 2005, judgment was entered by default against Derks in the sum of AUD246,033.07 inclusive of interest and costs. On 11 August 2005, the National Court in Lae (in proceedings OS No. 750 of 2005) registered the foreign judgment. The registration has prompted Derks to make this application on the following grounds:
(a) that the ex parte hearing of the registration proceeding was in breach of natural justice and especially in breach of section 59 of the Constitution,
(b) that Derks although having notice of Queensland Supreme Court proceeding did not have sufficient time to defend the proceeding,
(c) that enforcement of the judgment would be contrary to public policy,
(d) that the judgment was obtained by equitable fraud and should be set aside.
The issues
4. The issues are apparent from the grounds raised. They are as follows:
5. But it is necessary, at the outset, to appreciate the mandatory aspect of section 5 (1) of the Act.
The mandatory force of section 5 (1) of the Act
6. Section 5 (1) of the Act is mandatory and not merely permissive. It provides:
"(1) On application duly made by any party against whom a registered judgment may be enforced, the registration of the judgment –
(a) shall be set aside if the registering court is satisfied that ...."
7. By the use of the word "shall", registration of a foreign judgment should be set aside upon a finding of a ground specified under section 5 (1) of the Act. The discretion to set aside is only found in section 6 of the Act, which is presently irrelevant to the grounds in question.
8. Thus, in this case, Derks only needs to discharge the onus on him to prove or demonstrate, with the support of credible evidence or proper legal principles, the existence of a ground. Whether the foreign judgment is set aside depends on Derks discharging the onus bestowed upon him.
Applicability of natural justice - Section 59 of the Constitution
9. This ground is not sourced from section 5 (1) of the Act but from the Constitution. Section 59 of the Constitution adopts the common law principle of natural justice which minimum requirement is the duty to act fairly and, in principle, to be seen to act fairly.
10. Derks’ complaint is that the ex parte hearing of the registration proceeding offends section 59 of the Constitution and the principles of natural justice. Consequently, the registration should be set aside.
11. The duty to act fairly and be seen to act fairly under section 59 of the Constitution is the source of most procedural laws, rules and regulations. In the case of Ambrose Vakinap v Thaddeus Kambanei (2004) N3094, for instance, it was held that because the Constitution is supreme, a legislation which does not adopt the common law principles of natural justice, which is entrusted in section 59 of the Constitution, must observe the rules of natural justice, the minimum requirement of which, is to act fairly or be seen to act fairly.
12. Consistently, under section 4 of the Act, Rules of Court may be made in respect of proceeding for registration and setting aside of registration of foreign judgments. The relevant Rules of Court are found in Order 13 Division 9 of the National Court Rules. Rule 69 of Order 13 of the National Court Rules provides for the mode of commencement of proceeding and relevantly states that the judgment creditor may, unless the Court otherwise orders, proceed with the registration proceeding without service of the summons on the judgment debtor. It seems on its face that Order 13 Rule 69 of the National Court Rules is contrary to the principles of natural justice.
13. In the context of reciprocal enforcement, however, the registering country’s international strategic and economic interest supports the rebuttable presumption that a foreign judgment is valid and, for that reason, should be expeditiously registered and enforced in the registering country. However, as a balancing act, it is in the registering country’s public interest that where any of the grounds under section 5 (1) of the Act is proved, it is mandatory upon the courts to set aside the foreign judgment. Order 13 Rule 69 of the National Court Rules is, therefore, based on sound principles of law and practice pertaining to enforcement of foreign judgments, and is, therefore, not inconsistent with the principles of natural justice.
14. In this case, O’Dwyer took full advantage of the option to proceed ex parte in accordance with Order 13 Rule 69 of the National Court Rules. The ex parte registration of the foreign judgment in question is, therefore, in order.
15. The first ground of the application is, therefore, without merit.
Insufficient notice of foreign proceeding
16. Derks’ second ground of the application is based on section 5 (1) (iii) of the Act. A foreign judgment will be set aside where the judgment debtor, being the defendant in the proceedings in the original court, did not (notwithstanding that process may have been duly served on him in accordance with the law of the country of the original court) receive notice of those proceedings in sufficient time to enable him to defend the proceedings and did not appear.
17. Derks’ argument is that while he had notice of the Queensland Supreme Court proceeding, he did not have sufficient time to defend it. The merits of this argument are obvious from the history of the proceeding in Queensland.
18. Derks engaged the services of O’Dwyer on 9 November 2001. As alluded to, Derks was involved in a matrimonial proceeding where he alleged that his wife was involved in fraudulent dealings concerning a property which was worth millions of Australian Dollars. In the end, a Bill of Costs for AUD286,777.91 was prepared by a legal cost consultant and personally served on Derks by lawyer Nigel Merrick (Merrick) on 19 January 2005.
19. Service of the Bill of Costs was effected on Derks at his residence at Section 1 Allotment 71, Butibam Road, Lae. Upon receiving the documents, Derks was upset and threatened that the Bill of Costs would end up in the rubbish bin. Merrick responded by advising Derks that if he was unhappy with the bill, he should contact O’Dwyer or he should challenge the bill. Judgment would be obtained against him if he threw the Bill of Costs in the bin and did not dispute the bill. I do not think the Bill of Costs was thrown into a bin.
20. Bearing in mind Derks’ reaction at the time of service, at the top of the first page of the Bill of Costs is a forewarning note in the following terms:
"1. If you do not agree with anything in this Bill, you must, within 28 days of the Bill being served on you:
(a) make an agreement with the person who prepared the Bill and request the Court to make a Consent Order in the terms of the agreement; or
(b) file at the Court a copy of the Bill and a notice disputing the Bill.
"2. A notice disputing the Bill must identify each item in dispute, give the reasons for the dispute and state the amount (if any) offered in substitution for the amount specified in the Bill.
"3. If you file a notice disputing the Bill, you must also serve a copy of the notice disputing the Bill on the person who prepared the Bill.
"4. If you file a notice disputing the Bill, the Bill will be listed for a Taxation hearing before a Taxing Officer at any time and place of endorsement on the notice disputing the Bill."
21. At the time of service, Derks was also served with a Costs Notice. In Part 3 of the Costs Notice is the heading "Disputing the itemised account". Under this heading is a reminder in these terms:
"You have the right to dispute a lawyer’s itemised costs or any part of it, subject to the time limits and other matters mentioned below. While an account is being disputed according to the procedures set out in this brochure, the lawyer cannot sue for those costs."
22. The brochure goes on to state in a user friendly format that Derks had 28 days upon receipt of the itemised costs account to inform the lawyer that he disputes the itemised costs account by serving a Notice Disputing Costs Form 15 on O’Dwyer.
23. The 28 days lapsed on 16 February, 2005, at which time Derks had not taken steps either to renegotiate and enter into an agreement for a new Bill of Costs or to complete and forward a Notice Disputing Costs to O’Dwyer.
24. On 29 March 2005, which is an additional period of six weeks, a Claim and a Statement of Claim was filed by O’Dwyer against Derks for the sum of AUD286,777.91 in accordance with the Bill of Costs. The Claim and Statement of Claim were served on Derks by Merrick on 6 April 2005. Endorsed on the Claim is the following forewarning:
"TAKE NOTICE that you are being sued by the plaintiffs in the Court. If you intend to dispute this claim or wish to raise any counterclaim against the plaintiffs, you must within 28 days of service upon you of this claim file a Notice of Intention to Defend in this Registry. If you do not comply with this requirement Judgment may be given against you for the relief claimed and costs without further notice to you."
25. The forewarning is consistent with the Uniform Civil Procedure Rules of the Queensland Supreme Court. Under the said Rules, judgment may be obtained where no notice of intention to defend with a defence is filed or a defence is filed but the plaintiff seeks summary judgment.
26. In anticipation of Derks filing a Notice of Intention to Defend and Defence, a Supreme Court Application for Summary Judgment was earlier filed and on 6 April 2005, served together with the Claim and Statement of Claim on Derks. The 28 days lapsed on 4 May 2005. Derks had defaulted by 5 May 2005. Derks did not file a Notice of Intention to Defend or Defence. Judgment was entered against Derks on 9 May 2005 for AUD246,033.07 inclusive of interest and costs.
27. In his affidavit sworn on 9 September 2005, Derks deposed that he could not read the month on the application for judgment. His brother attended the Supreme Court hearing on 5 May, 2005, and he was advised that a new date would be given. He was never advised that the case was set down for 9 May 2005.
28. In any event, Derks had not filed a Notice of Intention to Defend or Defence by 5 May 2005. It would not have made any difference if Derks was told of the new date. He had already defaulted by 5 May 2005.
29. Derks demeanour and disposition at the time of service of the Bill of Costs and his subsequent failure to take steps to defend himself demonstrate that his lack of action and response were by choice and design. Derks deliberately or negligently failed to defend the Australian proceeding. His actions, with respect, were unreasonable, and equity will not come to the aid of a litigant who sleeps on his rights. Derks had sufficient notice and had sufficient time to defend himself but he chose to sleep on his right to defend himself.
30. In the circumstances, Derks has failed to persuade the Court that he was short served and was not able to defend himself. This ground must also fail.
Enforcement of foreign judgment and public policy
31. The third ground of the application is that it would be contrary to public policy to enforce the judgement. Under section 5 (1)(v) of the Act, the registration of foreign judgment should be set aside where its enforcement would be contrary to public policy of the registering court.
32. The issue of public policy was discussed in the case of Francis Kalyk, Anthony John Deegan, and Bruce William Hansen v Atlas Corporation Pty ltd (1998) N1760. Kapi, DCJ (as the Chief Justice then was) noted that public policy is a "vague and uncertain term". His Honour then referred to Lord Atkin’s definition that whether an act or omission is against public depends on whether "...harm to the public is substantially incontestable...." His Honour also cited a similar remark by Lord Wright, that whether an act or omission is against public policy depends on "...what are the definite propositions as to what interest of the State or what injury is supposed to be involved."
33. Given its vagueness and uncertainty, public policy could only be better understood by the peculiar facts and circumstances of each case. In that connection, what "is contrary to public policy in one era might not be considered contrary to public policy in another era where views of morals or what is publicly acceptable may have changed: De Santis v Russo (2001) QSC 65.
34. The cause of action in Francis Kalyk, Anthony John Deegan, and Bruce William Hansen v Atlas Corporation Pty ltd (1998) N1760, for instance, was an action for recovery of legal fees which could have been commenced in the courts in Papua New Guinea. It was argued that registration was against public policy because the institution of proceeding overseas means that the judgment debtor was denied his domestic procedural rights relevant to defending a claim for recovery of legal fees. His Honour found that given the procedural similarities of the foreign court with ours, the enforcement of the judgment would not be contrary to public policy.
35. However, a registration of a foreign judgment against a company already in liquidation in Papua New Guinea without the consent of the appointed liquidator, whose consent is required under section 298(1) (c) of the Companies Act, is contrary to public policy: Bexhill Funding Group Limited v Basumel Limited (2006) N3092, per Davani, J.
36. Similarly, a foreign judgment may be contrary to public policy if it is decided on a law which is not acceptable to the public policy of the registering forum, such as a judgment for wages of a prostitute or a terrorist: see Professor Nygh’s Conflict of Laws in Australia 6th ed 1995, at page 157, which was cited by Tamberlin J, who was dealing with the same issue, in Stern v National Australia Bank [1999] FCA 1421. Professor Nygh also says that a foreign judgment "may also be contrary to public policy because it was obtained in a manner obnoxious to the law of forum such as duress, or undue influence ...."
37. Furthermore, a "transaction that is valid by its foreign governing law should not be nullified on this ground unless its enforcement would offend some moral, social or economic principle so sacrosanct in English eyes as to require its maintenance at all costs and without exception": Cheshire and North’s Private International Law, 12th ed 1992 at 129, which was also cited to by Tamberlin, J.
38. Tamberlin, J eventually summarised his analysis of the principles on public policy, as follows:
"The thread running through all the authorities is that the extent to which the enforcement of the foreign judgment is contrary to public policy must be of a high order to establish a defence. A number of the cases involve questions of moral and ethical policy; fairness of procedure, and illegality, of a fundamental nature."
39. Obviously, Tamberlin J is also saying that public policy considerations also require restraint in relation to the setting aside of registration of a foreign judgment. As earlier mentioned, the registering country’s international strategic and economic interest supports the rebuttable presumption that a foreign judgment is valid and, for that reason, should be expeditiously registered and enforced in the registering country. In the common law language, Lord Simon in Vervaeke v Smith [1983] AC 145 at 164 puts it nicely, thus:
"There is little authority for refusing, on the ground of public policy, to recognise an otherwise conclusive foreign judgment – no doubt because the conclusiveness of a judgment of a foreign court of competent jurisdiction is itself buttressed by the rule of public policy...the ‘commonwealth’ in conflict of laws extending to the whole international community."
40. Consistently, a judgment creditor, under Order 13 Rule 69 of the National Court Rules, is permitted to commence registration proceeding ex parte. This privilege is matched by the mandatory force of section 5 (1) of the Act in the setting aside of registration provided the judgment debtor is able to establish his ground.
41. In relation to the question of proof of fraud, given the gravity of an allegation of fraud, I rely on and adopt as sound principle of law the decision in De Santis v Russo (2001) QSC 65, where it is stated at para. 16:
"It is accepted in Australian courts that, in respect of foreign judgments, it is not necessary to show that fresh evidence has been found since the original judgment. It is sufficient to show that the foreign court was misled into coming to a wrong decision by evidence which was false. In order for this court to find fraud, however, the proof "should be clear and cogent such as to induce, on a balance of probabilities, an actual persuasion of the mind as to the existence of the fraud."
42. The requirement for "clear and cogent" proof is itself already part of the underlying in relation to election cases where allegations of fraud are often raised. see Re Moresby North East Parliamentary Election (No. 2): Goasa Damena v Patterson Lowa [1977] PNGLR 448.
43. With all of the guiding principles on public policy in mind, the argument by Derks on public policy is that ordinary people are entitled to the full protection of the law, including the protection afforded by the laws, rules and regulations relating to the legal profession and its relationship with clients. It is submitted that the courts have adopted and espoused very stringent rules of practice relating to lawyers suing their clients for fees. The general rule, it is submitted, is that no lawyer may sue for his fees unless the court is satisfied that the costs are fair and reasonable and that the client is fully informed as to the costs of disbursements, the actual nature of the work done and the actual time spent, and that the client be given a real opportunity to decide whether or not to keep on incurring costs.
44. Relevantly, Derks’ factual basis for his arguments, as summarized by counsel, is that he consistently requested for bills in taxable form to be furnished to him but same was not done. He Derks was not provided with the bills in taxable form prior to January 2005. When the bill was finally delivered it was in voluminous form for work done over which Derks had no control or any say in. O’Dwyer did not seek Derks’ consent to incur substantial ongoing costs. O’Dwyer knew that Derks did not have legal representation and knew that it was unlikely that he could understand the bill, check on the times and charges claimed, and deal with it in a manner required or appreciate what he was supposed to do.
45. I am, with respect, not sufficiently persuaded by these arguments.
46. Regardless of whatever happened or did not happen, Derks was given the final opportunity in very plain terms to dispute the Bill of Costs but he chose not to. He was given the final opportunity to renegotiate and agree on a new Bill of Costs with O’Dwyer but he chose not to. He should have filed a Notice of Intention to Defend but he chose not to. He should have filed a Defence but he chose not to. He has not applied to set aside the foreign judgment. He has not appealed against the foreign judgment. Derks is not an ordinary person in Papua New Guinea. He is a company director and businessman. He has been involved in legal proceedings in Papua New Guinea in the past in his own right and through his company, Cartrans Limited. Derks is no simple man. For a man of his standing, his actions were unreasonable.
47. Derks knew or must have known the gravity of his obligation to settle his legal bills. Derks knew or must have known that it was important for him to go through the Bill of Costs and determine the nature of the work done and the corresponding charges. Derks knew or must have known that if he did not understand the Bill of Cost, he should have sought the services of an advisor. Derks knew or must have known the serious consequences of not disputing the Bill of Costs. Derks knew or must have known the serious consequence of failure to file a Notice of Intention to Defend and Defence. But he chose to be consistently unreasonable.
48. In the circumstances, Derks has only himself to blame for his demise. In any event, the cause of action which gave rise to the judgment in question is also available in this jurisdiction: Francis Kalyk, Anthony John Deegan, and Bruce William Hansen v Atlas Corporation Pty ltd (1998) N1760. Derks has, therefore, failed to demonstrate that enforcement of the judgment in question would be contrary to this forum’s public policy. In the circumstances, this ground must also fail.
Setting aside on ground of equitable fraud
49. Derks final ground for the application is based on section 5 (1) (iv) of the Act. Registration of a foreign judgment should be set aside where the judgment was obtained by fraud. Derks is, however, relying on the principle of equitable fraud.
50. The factual basis in support of this ground is that O’Dwyer’s conduct was unreasonable and unconscionable in that he consistently failed to maintain dialogue with Derks and keep Derks informed of the mounting legal bills. As alluded to Derks consistently requested for bills in taxable form to be furnished to him but same was not done. Derks was not provided with the bills in taxable form prior to January 2005. When the bill was finally delivered it was in voluminous form for work done over which Derks had no control or any say in. O’Dwyer did not seek Derks’ consent to incur substantial ongoing costs. O’Dwyer knew that Derks did not have legal representation and knew that it was unlikely that he could understand the bill, check on the times and charges claimed, and deal with it in a manner required or appreciate what he was supposed to do.
51. Fraud and equitable fraud, unfortunately, are not the same. The principle of equitable fraud is summarised by Owen J in the South Australian Supreme Court case of The Bell Group Ltd (In Lid) & Ors v Westpac Banking Corporation & Ors [2001] WASC 315 (19 December 2001), par. 102, in the following manner:
"I think it must be accepted that fraud in equity is a much wider concept than fraud at common law.... An equitable fraud can be committed in circumstances which the common law would regard as innocent. It must also be borne in mind that equity acts according to conscience and is adept at fashioning remedies (and doctrines) to meet circumstances that offend conscience. This, of course, is subject to the stricture that it must stem from established principle rather than from "idiosyncratic notions of fairness and justice". Nonetheless, in so many areas it is said that the categories of cases in which equity will intervene are not closed. Equitable fraud is one of them: La Rosa; Ex parte Norgard v Rocom Pty Ltd (1990) 21 FCR 270 at 288."
52. The principle of equitable fraud is part of the underlying law. It was imported through the adoption of the principle of proprietary estoppel: PNG Ready Mixed Concrete v Pty Ltd v The Independent State of Papua New Guinea [1981] PNGLR 396. In Steamships Trading Co Ltd v Garamut Enterprises Ltd (2000) N1959, Sheehan, J. held that non-compliance with procedures pertaining to rezoning of State land from public open space to commercial space tantamount to equitable fraud and the grant of the commercial lease was a nullity.
53. In Pinpar Developer Pty Ltd v TL Timber Development Pty Ltd (2006) N3075, Gavara-Nanu, J. held that procurement of landowners’ signatures by a Logging Contractor who had no capacity to explain the terms of the Agreement is unconscionable and is equitable fraud. It seems also that a finding of equitable fraud could result in the removal of the corporate veil: Odata Limited v Ambusa Corporate Oil Mill Limited & National Provident Fund Board of Trustees (2001) N2016, per Kandakasi, J.
54. On the other hand, fraud, according to Lord Herschell in Derry v Peek (1889) 14 App. Cas. 337, is false statement "made knowingly, or without belief in its truth, or recklessly, careless whether it be true or false." According to Lord Esher in Le Lievre v Gould [1893] UKLawRpKQB 27; [1893] 1 QB 491 at 498, fraud is "such a terrible thing to bring against a man that it cannot be maintained in any court unless it is shown that he had a wicked mind."
55. Fraud is obviously of a higher order than equitable fraud. The distinction is explained by Lord Lindley in a decision by the Privy Council in the New Zealand case of Assets Company Ltd v Mere Roihi and Others [1905] UKLawRpAC 11; [1905] AC 176, as follows:
"Passing now to the question of fraud ... by fraud in these Acts is meant actual fraud, i.e., dishonesty of some sort, not what is called constructive or equitable fraud – an unfortunate expression and one very apt to mislead, but often used, for want of a better term, to denote transactions having consequences in equity similar to those which flow from fraud."
56. Consequently, when statutorily prescribed, fraud means actual fraud and not equitable fraud. In The Papua Club Inc v Nusaum Holdings Limited (No. 2) (2004) N2603, Gavara-Nanu J., who also referred to Assets Company Ltd v Mere Roihi and Others [1905] UKLawRpAC 11; [1905] AC 176, observed that "fraud in s. 33 (1) (a) of the Land Registration Act, is not defined anywhere in the Act, but s.45 (1) makes it clear that fraud means more than constructive or equitable fraud."
57. In the context of enforcement of foreign judgments, equitable fraud is more of a domestic issue and should be left to the review processes of that court to deal with. Equitable fraud may, however, be relevant to ecommerce disputes and dispute resolution in the cyberspace. The nature of the transaction could persuade the courts into concluding that statutory fraud includes equitable fraud. In the meantime, a foreign judgment, in my view, should not be impeached on the basis of equitable fraud.
58. As decided in The Papua Club Inc v Nusaum Holdings Limited (No. 2) (2004) N2603, when used in section 5 (1) of the Act, fraud means actual fraud and not equitable fraud because, in the words of Lord Simon in Vervaeke v Smith [1983] AC 145 at 164, "the conclusiveness of a judgment of a foreign court of competent jurisdiction is itself buttressed by the rule of public policy."
59. Ultimately, Derks has failed to show that the foreign judgment in question could be impeached on the basis of equitable fraud, particularly when, as have been found, Derks has only himself to blame for his demise. For the foregoing reasons, this ground of the application must also fail.
Conclusion
60. The application to set aside registration of the foreign judgment was made on the basis of breach of natural justice; insufficient notice; public policy and equitable fraud. On breach of natural justice, it was argued that the ex parte hearing of the registration proceeding was contrary to the principles of natural justice. However, the ex parte proceeding is in accordance with Order 13 Rule 69 of the National Court Rules and is not a breach of natural justice. On insufficient notice, on the evidence, Derks was not short served. He had ample time to defend the proceeding but he chose not to.
61. On public policy, Derks argued that he was not kept informed of and did not expect a substantial bill. But when given the chance he squandered his opportunity to dispute the bill. He has only himself to blame for his demise. In any event, the cause of action which gave rise to the judgment in question is available in this jurisdiction and its enforcement would not be contrary to the public policy of this forum. On equitable fraud, fraud, when used in section 5 (1) of the Act, means actual fraud and not equitable fraud. Derks failed to show that the foreign judgment in question could be impeached on the basis of equitable fraud.
62. For the foregoing reasons, the application is dismissed with costs which, if not agreed, shall be taxed.
Orders accordingly.
__________________________________
Warner Shand Lawyers: Lawyers for the Plaintiffs
Aitsi Bray Lawyers: Lawyers for the Defendants
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