Downs Distributing Co Pty Ltd v Associated Blue Star Stores Pty Ltd (In Liq) [1948] HCA 14

Downs Distributing Co Pty Ltd v Associated Blue Star Stores Pty Ltd (In Liq) [1948] HCA 14

The transaction was not in the ordinary course of business; the circumstances objectively gave the defendant reason to suspect insolvency, excluding protection as a purchaser, payee, or encumbrancer in good faith under s.95(2)(b), thus the payment constituted a voidable preference and must be repaid to the liquidator. Ex parte James did not apply to prevent relief.

Jurisdiction
Australia
Procedural Posture
Appeal / Judgment on Appeal
Outcome
appeal dismissed
Legal Topics
['voidable Preference' 'winding Up' 'ordinary Course of Business' 'good Faith' 'onus of Proof']

Case Brief

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Procedural Posture

Appeal / Judgment on Appeal

  1. 1 ['Whether the transaction between the companies was a voidable preference under s.95 of the Bankruptcy Act 1924-1946 as applied by s.298(1) of the Companies Act 1936-1940 (NSW)' 'Whether the defendant was a purchaser, payee, or encumbrancer in good faith and for valuable consideration in the ordinary course of business' 'Whether the principle in Ex parte James applied so as to prevent the order to repay']

Ratio Decidendi

The transaction was not in the ordinary course of business; the circumstances objectively gave the defendant reason to suspect insolvency, excluding protection as a purchaser, payee, or encumbrancer in good faith under s.95(2)(b), thus the payment constituted a voidable preference and must be repaid to the liquidator. Ex parte James did not apply to prevent relief.

Court Disposition

appeal dismissed

Orders

  • ['Appeal dismissed with costs.']