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October 11, 2017 By Resolution Legal Melbourne

When is a penalty not really a penalty?

When there is an ancient custom about “physical tokens of earnest.” In other words, it’s time to talk about deposits.

Lawyers spent many years arguing over the clause in the standard contract produced by the Real Estate Institute of Victoria (REIV) which stated that if the purchaser defaulted, the deposit could be forfeited to the vendor.

Forfeiture of the deposit was simple enough if the vendor was holding it.  They would just keep it.  However, there were many cases where the contract ended before the full deposit was paid.  This led to many arguments over whether the deposit could be forfeited when it had never been paid in the first place.  In other words, could the vendor keep something that the vendor did not have?

The REIV tried to address this by changing the standard form contract.  Clause 28.4(a) of the standard contract now says that if the contract ends by a default notice given by the vendor “the deposit up to 10% of the price is forfeited to the vendor as the vendor’s absolute property, whether the deposit has been paid or not”.

I have never been convinced that this fixed anything.  If you cannot forfeit a deposit that was never paid, then a contract stating that the unpaid deposit is forfeited doesn’t really change that fundamental problem.  Still, at least the change made it clear that everyone involved intended the section to apply to deposits that had not yet been paid.

The alternative would have been to get rid of the concept of forfeiture of unpaid deposits altogether.  It would be so much simpler just to say that on default:

  • If the deposit had been paid it was forfeited
  • If the deposit had not been paid, the purchaser would have to pay the balance of the deposit to the vendor immediately, meaning the balance of the deposit would be a debt due and payable immediately.

I’m not sure why the REIV did not take this approach, but there is at least one good reason, which can be found in the recent decision of the Supreme Court of Victoria in Simcevski v Dixon (No 2) [2017] VSC 531 (8 September 2017).

That case was not precisely about an unpaid deposit.  In Simcevski, the vendor and the purchaser seem to have been trying to solve a slightly different problem.  What do you do when the purchaser does not want to pay a 10% deposit (or they can’t afford to do this), but the Vendor still wants to be able to retain 10% of the purchase price on default?

The creative solution that they came up with was that they agreed on a 5% deposit, which would be forfeit on default as usual, and also agreed that if there was a default, the purchaser would pay another 5% of the purchase price.

This meant that Clause 28.4(a) of their contract said that if the contract ends by a default notice given by the vendor:

“the deposit up to 10% of the price is forfeited as the vendor’s absolute property, whether the deposit has been paid or not”

The Court found that the vendor was entitled to keep the 5% deposit that had actually been paid.  The other 5% that was due to be paid if there was a default was a different matter.

A Court will not enforce a provision of a contract if that provision is a “penalty”.  Parties can agree on an amount to be paid if a contract is breached, but the amount is generally required to be related to the amount of the loss that the innocent party can expect to suffer.  If the amount payable on breach is out of all proportion to the actual loss, this is a penalty and a Court will not enforce it.

This leads to the obvious question of why a vendor should ever be allowed to keep a 10% deposit if there is a default.  There is no clear reason why a vendor would lose 10% of the price of a house in this situation.  The vendor will certainly have some extra costs, like advertising and agent’s commissions, but there is no particular reason to believe that those costs will be 10% of the price.  It seems unlikely that those costs would be $30,000 on the re-sale of a two bedroom unit in Bayswater but $150,000 on the resale of a 4 bedroom house in Mont Albert. In any case, in the current market the vendor will often sell the property for a higher price than the original purchaser had agreed to pay and the vendor may end up suffering no loss at all.

So, if penalties cannot be enforced, why is it okay for vendors to keep a deposit? In Simcevski, the Court effectively said that this is just the way things are, or, as Lord Browne-Wilkinson said in the case of Workers Trust and Merchant Bank Ltd v Dojap Investments Ltd:

“The special treatment afforded to such a deposit derives from the ancient custom of providing an earnest for the performance of a contract in the form of giving either some physical token of earnest (such as a ring) or earnest money.”

This might be a good time for Parliament take a look at this issue. I’m not sure we should base any current law on ancient customs involving tokens, particularly when this makes life just a little bit harder for first home buyers.  However, at least until that happens, then the general rule against penalties does not stop a vendor from keeping a purchaser’s deposit if there is a default.

None of this was any help to the vendor in the Simcevski case.  The Court found, effectively, that if the whole 10% had been a deposit, then it would not have been a penalty.  However, the word “deposit” in Clause 28.4 had literally been crossed out.  So, in that particular contract, it was clear that the extra 5% was not part of the deposit.  This meant that it was a penalty and the purchaser did not have to pay it.

The Court also referred to a New South Wales case called Iannello v Sharpe, which suggested that calling the extra 5% a part of the deposit probably would not have helped.  If the extra 5% was only payable on default, it was still a penalty no matter what the parties called it.

What we learn from this case is that if you are a vendor and you want to recover to deposit if there is a default, make sure the contract clearly requires payment of the deposit, by a set date, in full.

The other things we can learn from this case (and most of the cases that have ever gone to Court) is that it’s important to get good legal advice before you make any changes to a standard form contract.  Crossing out a few words may seem like a good solution, but it can result in lengthy, expensive litigation with unsatisfactory results.  In Simcevski, the purchaser wanted their deposit back, the vendor wanted an extra 5% of the price, and neither of them got what they asked for.  The judgment does not say who is paying the costs, but it seems likely that both parties will end up with a legal bill.

October 9, 2017 By Resolution Legal Melbourne

The Coaches’ Dilemma

Years ago, I was watching an  interview with the coach of one of Victoria’s less successful football teams, a few days before they were due to play the team sitting on top of the ladder.  Everyone in Australia, including the interviewer, assumed they were going to lose. This was so long ago that I can’t remember which team it was, or who they were due to play against.  I do remember that they did in fact go on to lose the game as expected.

The interviewer asked the coach how the coaching staff prepare for a match in those circumstances.  The answer was quite fascinating.

The coach said that he would do what he always did, which was to spend the week looking at match-ups, trying to work out what the other team would do tactically and coming up with plans to counter those tactics.  He then went on to say that when you spend the week doing that, by Thursday you are always convinced that you are going to win.  Unfortunately, there’s also someone on the other side doing exactly the same thing.

This is something that everyone, especially lawyers, should remember whenever they are dealing with a legal dispute.

Everyone who goes into Court goes in with a strategy and plans for how they will win, but only one of them is actually going to succeed.   Being a lawyer is a little bit like being a football coach in that it’s one of the few jobs where while you are working very hard to succeed in dealing with a complex issue, someone else is working equally hard to try to stop you from winning.

When people in a dispute, or their lawyers, forget about this, that’s when people make poor decisions about whether to settle a case, and leave themselves open to the terrible experience of losing a case and have to pay huge amounts in legal costs.

This is why its always really important to sit down at the start of any dispute and have a very careful look at the case so you can work out the strengths and weaknesses.  It’s also important to keep doing this regularly for as long as the dispute continues.  Most of all, it’s essential that the lawyers do not get so focused on strategy that the forget the big picture.

September 21, 2017 By Resolution Legal Melbourne

Mediation – A Beginner’s Guide

No one enjoys being involved in a legal dispute.  Even lawyers tend to avoid these unless they are getting paid to turn up.  Having a legal problem is a lot like having a sore tooth.  You didn’t ask for it, you don’t want to spend money on it, and it would be great if it would just go away.  Unfortunately, as my dentist often reminds me, these things hardly ever go away by themselves.  If you have to deal with a dispute, it’s best to do it quickly, before things get any worse.  Dealing with the problem quickly will save you a whole lot of stress, and a whole lot of money.

Usually, the person you are in the dispute with is not any happier than you are with the situation.  It doesn’t matter who started the dispute, or who is threatening to go to Court over it, I will bet you that everyone involved would rather be doing something else.  Unfortunately, even when no one wants to continue with a dispute, sometimes neither person wants to be the first to make an offer.  This could be because people are angry with each other, it could be because people think they will look weak if they make the first move, and sometimes it’s just that people do not know where to start.

This is why mediation is worth a try.  If you suggest mediation, you are not offering anything.  There is a really good chance that the other person will secretly be relieved that you have suggested this and they will jump at the opportunity.

Once you have agreed to mediate, you need to find a good mediator and a suitable venue.  I can help you there.

So, now that arrangements are in place and a date has been set, how do you prepare for mediation?  Here’s a few tips.

Don’t worry too much about what will happen.  

One great thing about mediation is that the process is confidential.  You can have an open discussion, and even make offers to settle the dispute, without having to worry that what you say will be used against you later.  Another great thing about mediation is that the mediator cannot impose any result on you.  There is no judge or jury making decisions about your case.  There will only be a result if you and the other person in the dispute agree on exactly what will happen.  In other words, you cannot “lose” a mediation.

I know this is obvious, but good preparation is essential.  

Even though you can’t lose, you still want to be well prepared, because this gives you the best chance of getting a fair settlement and being able to move on from the dispute.  Going in to a mediation, you need to know:

  • What are the main issues to be discussed?
  • What do you want to say about those issues?
  • What do you want to achieve?
  • What are your alternatives if the dispute is not resolved?

If you can explain your position clearly, and the other person can do the same, you will at least get a pretty good idea of where you stand.  You might be closer to a solution than you thought.  If not, at least you’ll know what you are dealing with.

Consider getting some advice

No one ever goes to buy car without doing a bit of research first.  Even if you are great at negotiating with user car dealers, you will not know whether you have been offered a good deal unless you know what your other options are.  Mediation is no different, except that if a dispute has gone to mediation, it’s probably about something far more serious and important than which car to buy.

You can only assess whether the deal on offer is a good one if you know what your other options are.  You need to have an idea of what will happen if you cannot resolve the dispute and what opportunities, risks and costs may be involved.  Even though it will add a bit to your costs, it might be worthwhile to talk to a lawyer for an hour or two just to find out where you stand.

Remember that you can control this process

Mediation starts when everyone is ready and continues until someone decides it’s time to stop.  The process is flexible.  If you need time to consider an offer, or if you just need a cigarette or a cup of coffee, you can tell the mediator that you need a break.  If you don’t think it’s a good idea to be in the same room as the other person, you can ask your mediator to speak to each person privately.  If you think there’s nothing further you can achieve on the day but you want to come back another day, you can ask for that too.

Mediation is a process that exists solely to help you find a solution, so make sure you give your mediator feedback throughout the day about how you are travelling and what you think would be helpful to you.

 

Mediation is not a perfect process, but it’s almost always the best approach to a dispute.  A lot of people regret going to Court, but I don’t often hear anyone say they wish they hadn’t tried mediation first.

If you are unsure of whether mediation is the best approach to your situation, you can call me for a free, no obligation chat on 03 9998 9711.

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