Wilde v Australian Trade Equipment Co Ltd [1981] HCA 13

Wilde v Australian Trade Equipment Co Ltd [1981] HCA 13

Where registration of a charge out of statutory time is effected in reliance on a valid court order extending time, and a certificate of registration is issued, the statutory certificate is conclusive evidence of compliance with registration requirements under s. 103(2), even if the order extending time is subsequently set aside; accordingly, the charge is not void against the liquidator or creditors.

Jurisdiction
Australia
Procedural Posture
Appeal / Final Appellate Judgment
Outcome
Appeal dismissed with costs.
Legal Topics
['registration of Company Charges' 'priority of Secured Creditors' 'liquidation' 'interpretation of Statutory Certificates']

Case Brief

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Procedural Posture

Appeal / Final Appellate Judgment

  1. 1 ['Whether a registered charge is void against the liquidator and creditors when time for registration was extended by court order later set aside' 'Effect of certificate of registration under s. 103(2) of the Companies Act 1961 (Qld) when order extending registration is set aside']

Ratio Decidendi

Where registration of a charge out of statutory time is effected in reliance on a valid court order extending time, and a certificate of registration is issued, the statutory certificate is conclusive evidence of compliance with registration requirements under s. 103(2), even if the order extending time is subsequently set aside; accordingly, the charge is not void against the liquidator or creditors.

Court Disposition

Appeal dismissed with costs.

Orders

  • ['Appeal dismissed with costs.']