64 . Notice of originating motion (O. 54 r. 5)
IN THE SUPREME COURT OF WESTERN
AUSTRALIA
HELD AT PERTH CIV 1275
OF 2012
In the matters of:
1.
CIV 2157 of 2011 or GANNAWAY
-v- CHIN [2011] WASC 252;
2.
CACV107 OF 2008: JOINT
APPLICATION IN AN APPEAL PURSUANT TO R.44 OF SUPREME COURT (COURT OF APPEAL)
RULES 2005 DATED 25.7.2011 IN 44 PAGES;
3.
CIV 1877 of 2010 or RE HALL; EX
PARTE CHIN [2] [2011] WASC 155;
4.
CACV 107 of 2008 (No.2) or CHIN
-v- HALL [No 2] [2011] WASCA 96;
5.
P l of 2010 or Chin v Hall
& Ors [2010] HCASL 104 (26 May 2010 );
6.
CACV 107 of 2008 or CHIN -v-
HALL [2009] WASCA 216;
7.
CIV 1775 of 2008 or AUDREY
FRANCIS HALL as executrix of the estate of KENNETH DUNCAN HALL -v- CHIN
[2008] WASC 255;
And
In the matters of:
8.
CIV 2509 of 202 or LAW -v-
GANNAWAY as administrator of the estate of NANCY CLOONAN HALL [No 2] [2011]
WADC 195;
9.
CACV 53 of 2007 or
MICHELE-MAREE GANNAWAY as Administrator of the Estate of NANCY CLOONAN HALL v
AUDREY FRANCES HALL as Executrix of the Estate of the late KENNETH DUNCAN HALL
[No.2] [2010] WASCA 173;
10.
CACV 100 of 2008 or LAW v
AUDREY FRANCES HALL as Executrix of the Estate of the Late KENNETH DUNCAN
11.
CACV 106 of 2008 or LAW v
AUDREY FRANCES HALL as Executrix of the Estate of the late KENNETH DUNCAN HALL
[2008] WASCA 257;
12.
CACV 106 of 2008 or LAW v
AUDREY FRANCES HALL as Executrix of the Estate of the late KENNETH DCUNCAN HALL
[2008] WASCA 257 (S);
13.
CACV 53 of 2007 OR HALL v
AUDREY FRANCES HALL as Executrix of the Estate of the late KENNETH DUNCAN HALL
[2007]WASCA 94;
14. CIV 2073 OF 2003 or AUDREY FRANCES HALL As Executrix of the Will of
KENNETH DUNCAN HALL (DEC) v HALL [2007] WASC 34;
15. CIV 2509 of 2002 or MAURICE FREDERICK LAW, CHERYL LAW AND SPUNTER
PTY LTD -v- HALL [2005] WADC 75;
And
In the matter of an Ex-parte Application in CIV 2157
of 2011 for the Removal of the Errors Apparent on Court Records, pursuant
to RSC O 59 r 3 and subs 25(6),
33,
43 and 59 of the Supreme Court Act,
1935 for declarative orders of the jurisdictional errors,
the cancellation of the technical errors,
review the areas of dispute and the new trials of particular areas of dispute
(the Removal of Errors of Law Apparent on the Court Records).
BETWEEN
NICHOLAS NI KOK CHIN FIRST APPLICANT
MAURICE FREDERICK LAW SECOND APPLICANT
And
MICHELE-MAREE GANNAWAY As the Administrator of
The Estate of the late NANCY CLOONAN HALL FIRST RESPONDENT
AUDREY FRANCES HALL AS the Executrix of the
late KENNETH DUNCAN HALL SECOND RESPONDENT
EX-PARTE: NICHOLAS NI KOK CHIN
EX-PARTE: MAURICE FREDERICK LAW
------------------------------------------------------------------------------------------------------------
NOTICE OF ORIGINATING MOTION FOR
LEAVE PURUSANT TO RSC O 67 R.5 APPLICABLE FIRST APPLICANT AS PER ORDERS OF
MURRAY J IN CIV 1689 OF 2011 DELIVERED 11.1.2011.
------------------------------------------------------------------------------------------------------------
Date of Document:
7th day of February, 2012
Filed on behalf of: The First and Second Applicants in
Person.
Date of filing: 8th day of
February, 2012
Prepared by:
NICHOLAS NI KOK CHIN Phone & Facsimile: 08 92757440
387, Alexander
Drive Mobile
MAURICE FREDERICK LAW Phone: 08 92961555
P.O. BOX: 399 Mobile
------------------------------------------------------------------------------------------------------------
TAKE NOTICE that the Supreme Court [or Court of Appeal] will be moved at [Perth] on day the 18TH
day JUNE, of 2012 at the hour of 10.30 in the FORE noon, or so soon thereafter as
counsel can be heard, by counsel on behalf of the First Applicant Nicholas
Ni Kok Chin and the Second Applicant Maurice Frederick Law for Orders that:
1. The First Applicant (having been declared a
Vexatious Litigant by His Honour Murray J of the Supreme Court on 10.1.2012 in
CIV 1689 of 2011: Principal Registrar of
the Supreme Court of WA v Nicholas Ni Kok Chin [2012] WASC 7) BE GRANTED
LEAVE by a single judge of the Supreme Court of Western Australia pursuant to
s.6(1)(a) of the Vexatious Civil
Proceedings Act 2002 (WA) to JOIN the Second Applicant in these proceedings
(the LEAVE).
2. The LEAVE is for the purpose of instituting legal
proceedings for Judicial Review of the Jurisdictional Errors of their Honours
Master Sanderson, Owen JA, Simmonds J and Judge Sweeney, in CIV 1775 of 2008,
CACV 107 of 2008, CIV 2157 of 2011 and CIV 2509 of 2002 respectively (the
Respective Cases).
3. The Respective Cases be consolidated pursuant to
RSC O 83 on the ground that they represent causes or matters that affect one SINGLE
ISSUE (of the legal ramifications) of the falsification of court records by Solicitor
David Taylor’s in CIV1131 of 2006 on 10.2.2006 (which caused detriment and
economic deprivations to both the Applicants) for the purpose of quieting all
claims relating to that one subject matter, transaction or events (the Case for
Consolidation for the SINGLE ISSUE).
4. The Case for
Consolidation for the SINGLE ISSUE that has hitherto never been decided by the
four judges of the Respective Cases and therefore it is not barred by the
principles of res judicata for its
proper adjudication in these proceedings (Issue Not Barred by Res Judicata).
5. In order to
enable the single judge to grant the LEAVE and to deliver equal and fair
justice to both Applicants, His Honour shall have the responsibility of looking
into the FIFTEEN MATTERS of both Applicants to decide on the Issue Not Barred
by Res Judicata as a preliminary
first step to grant the said LEAVE (the Reason for Leave to be granted).
6. The proof for the SINGLE ISSUE is the subpoenaed
evidence provided by David Taylor to the President of the State Administrative
Tribunal in VR158 of 2011 on 29.11.2011 for which the Second Applicant had had the
chance to ascertain with his own eyes (the Proof).
7. The Errors of Law Apparent on the Court Records
arising from the Jurisdictional Errors of the Four Judges (once substantiated
by the Proof) need to be EXPUNGED from the court records for posterity (the
Expurgation).
8. The Supreme Court of WA is bound by law to unravel
the fraud upon the court pertaining to the SINGLE ISSUE and to proceed with the
Expurgation, otherwise, posterity shall hold the view that the fraud relating
to it has received and will continue to receive curial approbation and approval
into the future. This DOES NOT BODE WELL
FOR THE FUTURE and it would undermine the confidence of the public in our
judicial system of Western Australia, which has already been constructively
criticized by the President of Bar Association of British Columbia GORDON
TURRIFF QC who have made findings that
the Independence of the BAR being the sine
qua non to the Independence of Judiciary is present in Canada but is
lacking in Australia, particularly in Western Australia. This is supported by Acting Chief Justice
Spigelman of NSW findings that Australia should have a fourth pillar of
government, namely the Integrity Pillar of the Judiciary, which is also missing
in WA (the Expurgation of the Errors of Law Apparent Upon the Court Records).
8. The Status of the First Applicant as a Vexatious
Litigant is in the process of being rectified by himself for the purpose of
over-turning the decision and the staying of the costs order on the grounds of
the jurisdictional excesses of His Honour Justice Murray (The disputed status
of the First Applicant as a Vexatious Litigant).
AND for the following declarative
reliefs:
FURTHER ORDERS SOUGHT:
Both Applicants are seeking Declarative Orders
pursuant to s.25(6) of the Act,
to make binding declarations of rights,
which cannot be open to objection,
in terms of the following:
1.
The Respective Jurisdictional Errors or the
jurisdictional excesses of the four
judges namely Master Sanderson, Owen JA, Simmonds J and DCJ Sweeney consist of Their
Honours’ respective ERRORS OF FACTS and LAW derived from their respective
determinations of the SINGLE ISSUE of DAVID TAYLOR’S FALSIFICATION OF COURT
RECORDS IN CIV 1131 OF 2006 dated 10.2.2006 (the Respective Errors of the Four
Judges).
2.
Prior to 10.2.2006, the interests/rights of
the First and the Second Applicants were conflicting with each other BUT by
virtue of the wrongdoings of David Taylor pertaining to the SINGLE ISSUE perpetrated
upon his own client the Second Applicant and also upon his opposing solicitor
on 10.2.2006; these conflicting interests as from that date no longer conflicts
but are being merged into one of common interests in their common pursuit of their
single wrongdoer the learned David Taylor for the righting of the wrongs of the
SINGLE ISSUE. (The Common Interests of both Applicants).
3.
The nature of the Respective Errors of the
Four Judges vis-à-vis the Common Interests of both Applicants is now crystal
clear in the eyes of the public if one were to understand the law on the nature
of Jurisdictional Errors as propounded by His Honour the Acting Chief Justice
of NSW Justice Spigelman, which is annexed as an EXHIBIT to the Supporting
Affidavit of this Application (the Spigelman Jurisdictional Errors).
4.
The Spigelman Jurisdicitonal Errors
contains the following elements which can be defined in the FIFTEEN listed
matters of these proceedings, where each of the respective judges can be
reasonably found to have made at least one error in respect of the
non-exhaustive list of errors in terms of the following:
4.1. denial
of procedural fairness to either or both the Applicants,
4.2. identifying
the wrong issues,
4.3. asking
themselves the wrong questions;
4.4. ignoring
relevant materials;
4.5. relying
on irrelevant materials,
4.6. making
erroneous findings of facts or law;
4.7. reaching
mistaken conclusions of facts or law;
4.8. determination
of critical facts where there is no evidence;
4.9. irrational and illogical reasoning
in the fact finding process;
4.10.
making purported decisions which does not render them ex-functus officio;
4.11.
misapprehension of the law.
5. Master
Sanderson’s Jurisdictional Error dated 28.10.2008 is His Honour’s “NO NEXUS”
between the First Applicant’s Solicitors Work in CIV 1142 of 2005 and CIV 1131
of 2006 for the latter’s client Nancy Hall and the latter’s Consequent Removal
of the Second Applicant’s Spunter’s Caveats bearing Nos 1186052 and 1186053 from
parts of the estate of Nancy viz the
Hazelmere and Mt. Lawley Properties on 10.2.2006. The High Court’s rationalizes
in P1 of 2010 that the First Applicant must seek to establish that NEXUS so
that both the Applicants are enabled to obtain fair justice in accordance with
the applicable facts and law as Joint Applicants in these proceedings. The Nexus is established once the truth of
the SINGLE ISSUE is resolved by these Judicial Review Proceedings (The Just Solution
to Master Sanderson’s Error).
6. Owen
JA’s Error dated 9.12.2009 is caused by the mis-reception of fresh evidence by
the Court of Appeal in CACV 107 of 2008 that was caused by the error of “untruths”
of the Learned Registrar Powell’s letter dated 11.6.2009. That letter avoids the Just Solution to Master
Sanderson’s Error. The said Proof of the
Second Applicant in VR158 of 2011 dated 29.11.2011, once accepted into these
proceedings, shall bring about the Just Solution to Master Sanderson’s Error (The
Solution from VR158 of 2011).
7. The
Just Solution to Master Sanderson’s Error and The Solution from VR158 of 2011
shall correct the detriment and the economic deprivations of both the First and
Second Applicants wrought by the wrongdoings of the wrongdoer the learned David
Taylor with reference to the SINGLE ISSUE, in the following terms:
7.1.The
First Applicant shall be reinstated to his status as the former s.244 LPA
salvour of the Hazelmere and Mt.
Lawley
7.2. The
First Applicant shall be entitled to his just emolument from the estate of
Nancy Hall through its administrator upon the former being conferred the
salvour status by virtue of these proceedings (The First Applicant as the salvour of the estate had to continue to
salvour the estate first from the fraud of Mrs. Audrey Hall and later from the
clutches of the Administrator who refused to settle Nancy’s just debts to the
Second Applicant. Hence the reason for the escalation of the just emolument of
the First Applicant from the agreed price of $20k to the current claim of about
$150k and it continuing). The just
emolument is estimated to be about $150k for which the administrator has been given
notice of. The just emolument is to be
assessed by this Honourable Court to include the $20k held in trust by the solicitor
for Mrs. Audrey Hall, the executrix of the estate of Kenneth Duncan Hall through
her learned solicitor Mr. Anthony Prime and Pullin JA in prior proceedings (The
Just Compensation for the First Applicant).
7.3.The Second Applicant has
been denied his default judgment debts in DC CIV 2509 of 2002 in the sum of $151, 314.59 as from 10.10.2002 plus
interests as defined by paragraph 244 of the judgment of DCJ Sweeney in DC CIV
2509 of 2002 or LAW -v- GANNAWAY as administrator of the estate of NANCY
CLOONAN HALL [No 2] [2011] WADC 195 (Just Recompense for the Second Applicant).
7.4.The
First and Second Applicants shall also be recompensed for the removal of both
their New Caveats that was removed in error by His Honour Simmonds J in CIV2157
of 2011 dated 8 and 12.8.2011 (The Just Recompense for the Wrongful Removal of
Caveats).
8. The Parties involved in
these proceedings for LEAVE and the EXPURGATION pursuant to s. 6(6)(a) are the
following:
8.1.Both Mrs. Michele-Maree
GANNAWAY as the administrator of the estate of Nancy Cloonan Hall and her
solicitors are Messrs. Chris Stokes & Associates of Level 1 of No. 259, Hay
Street, PERTH WA 6000 are to be made parties to these proceedings as they are
involved respectively in CIV 2157 of 2011 for both Applicants for the Removal
of the NEW CAVEATS and in DC CIV 2509 of 2002 in respect of the liability of
Estate of Nancy Hall as the debtor of Spunter Pty Ltd or the Second Applicant
(the Parties against whom these proceedings are to be instituted).
8.2.Mrs. Michele-Maree
GANNAWAY as the administrator of the Estate of Nancy Hall in respect of the
SINGLE ISSUE of the falsifications of Court Records by David Taylor in so far
as they affect the judicial review of CIV 1775 of 2008 and CACV107 of 2008 (the
Rectification of the SINGLE ISSUE)
8.3.The Administrator was
agitating the issue of the fraud of Mrs. Audrey Hall in CIV 2073 of 2003 wrought
upon the estate of Nancy Hall as a result of a judgment debt of $2.3m given by
Jenkins J. (The fraud is clear: The administrator’s Solicitor Mr. Chris
Stokes produced a letter to the Second Applicant stating that no money changed
hands between Nancy Hall and her mortgagee Engineering Facilities Pty Ltd. The
mortgage was redeemed by the husband Mrs. Audrey Hall who is Nancy Hall’s
brother and again no money changed hands.)
This judgment had overridden the claims of the legitimate creditors i.e.
both the Claimants against the Estate of Nancy Hall (the Fraud of Mrs. Audrey
Hall).
8.4.The Administrator has effectively
dealt with the Fraud of Mrs. Audrey Hall by settling with her using the
mortgage money of $702k which she had taken out from a financier using the
estate of her late mother Nancy Hall as the pledge. She did this without regard to the rights of
the legitimate creditors in the persons of both the Applicants in these
proceedings (The Resolution of the Fraud of Mrs. Audrey Hall by the
Administrator to the detriment of the Applicants).
8.5.The Resolution of the
Fraud of Mrs. Audrey Hall by the Administrator to the detriment of the
Applicants is being evidenced by paragraph 8 of the Affidavit of the
Administrator sworn 9.8.2011 and filed in CIV2157 of 2011 (the Unjust
Enrichment of the Administrator).
8.6.As a result of The
Resolution of the Fraud of Mrs. Audrey Hall by the Administrator to the
Detriment of the Applicants and the Unjust Enrichment of the Administrator, the
Administrator is now bound by law to make restitution to the legitimate
creditors of the estate of Nancy Hall and she should not be reasonably seen to
be perpetuating the fraud that was first initiated by Mrs. Audrey Hall against
the Estate of Nancy Hall (the Restitution of the Applicants to their original
position as if the Fraud of Audrey Hall did not take place).
8.7.The learned David Taylor
of DTS Legal of Suite No.5/168, Guildford Road, MAYLANDS WA 6051, is to held accountable
for the detriment and the economic deprivations of both Applicants arising from
his wrong doings to both of them with reference to the SINGLE ISSUE (the
Accountability of David Taylor).
8.8.Mr. Chris Stokes of Chris
Stokes & Associates as the solicitor for the Administrator when dealing
with CIV 2157 of 2011 and DC CIV 2509 of 2002 was given DUE NOTICE by both the
Applicants to the following effects:
7.6.1. Mr. Chris Stokes must not
mislead the court with regard to SINGLE ISSUE in so far as it affects the Integrity
of the New Caveats No L550173 and L553
573 dated 23.2.2011 of both the Applicants.
But he resisted thereby effecting the unlawful removal of the New
Caveats through CIV2157 of 2011 through the Error of His Honour Simmonds J on 8
and 12 of August, 2011 (the Unlawful Removal of the New Caveats).
7.6.2. Mr. Chris Stokes owes his
duty to the court as a court officer in terms of his informing the court of the
SINGLE ISSUE, the Fraud of Mrs. Audrey Hall, working towards the Resolution of
Mrs. Audrey Hall’s Fraud, the Accountability of David Taylor and the
Restitution of the Applicants to their original position as if the Fraud of
Audrey Hall did not take place (the Duties of Mr. Chris Stokes).
7.6.3.
By virtue of the Duties of Mr. Chris Stokes not having been
discharged in a lawful manner by him as an officer of the court, he should be
held accountable for the losses of both the Applicants arising from the
wrongful removal of the New Caveats if the Administrator cannot make good the
damages and the detriment caused to both the Applicants (the Accountability of
Mr. Chris Stokes).
And that the costs of and
incidental to this application for the Removal of the Errors of Law Apparent on
the Court Records may be paid by First
Respondent.
And further TAKE NOTICE that the GROUNDS of this application for each of the above declaratory
reliefs are as follows:
1. GROUNDS FOR ERRORS OF
MASTER SANDERSON:
1.1. The SINGLE ISSUE of the falsifications of
the Court Records was never decided.
1.2. The First Applicant was deprived of his
salvour status derivative of the former s.244 Legal Practice Act, 2003 WA and
my Just Emoluments as the Salvour.
1.4. The Second Applicant was deprived of his
rights to seek claim of damages against his former solicitor David Taylor
emanating from the SINGLE ISSUE.
1.5. The Second Applicant is deprived of his
just debts as the legitimate creditor of Nancy Estate arising from the default
judgment.
1.4. Paragraph 6 of the judgment: “… first defendant has done nothing to preserve
the property…..”is an untruth because the First Applicant’s solicitor’s
work for part of the estate of Nancy Hall is the NEXUS for the Removal of the
Spunter’s or the Second Applicant’s Caveats BUT for the Just determination of
the SINGLE ISSUE.
2.1. The 20 cents cover-up story by Registrar
Powell in his letter dated 11.6.2009 found at page 136 of the Yellow Appeal
Book in CACV107 of 2008 is the Fresh Evidence
before Owen JA on 9.12.2009. This is
because Master Sanderson, as the primary decision maker on 29.10.2008 did not have
this evidence before him and this evidence was not available at that time and
could not have been obtained with reasonable diligence of the First Applicant (the
Fresh Evidence);
2.2. For
the Fresh Evidence to become admissible evidence for Owen JA on 9.12.2009, it (the
Fresh Evidence) must have a material effect in reversing the primary decision
of Master Sanderson in accordance with the applicable common law principle (Condition
for the Admittance of the Fresh Evidence);
2.3. The Jurisdictional Error of Owen JA is
constituted by His Honor’s refusal to comply with the Condition for the
Admittance of the Fresh Evidence as exemplified by the reason for judgment and
the findings of fact by Owen JA in paragraphs 54, 55, 57 of
the judgment of the Secondary Decision Maker. They therefore can reasonably be
faulted as Jurisdictional Errors warranting a Judicial Review by this Honorable
Court based upon the eleven grounds enumerated in Orders Sought No.7: (Owen JA’s
Jurisdictional Error).
2.4. The SINGLE issue of the falsification of
the Court Records is now proved beyond reasonable doubt by the Answer to the
Subpoena of David Taylor dated 29.11.2011 in VR158 of 2011 given to the
President of SAT, Justice Chaney (Contempt of Court Penalty for disobeying the
Subpoena).
3.
GROUNDS FOR THE ERRORS OF SIMMONDS J IN CIV 2157 OF 2011:
3.1. Simmonds J was required to make a
determination on the SINGLE ISSUE of the falsification of court records by
David Taylor for the purpose of justifying the removal of the New Caveats of
both Applicants (the issues before Simmonds J).
3.2. If Simmonds J did not fall into Jurisdictional
Errors, he would have relied upon the Fresh Evidence, the
Condition the Admittance of the Fresh Evidence and therefore recognize Owen
JA’s Jurisdictional Error and the eleven criteria for Jurisdictional Errors in
FURTHER ORDERS SOUGHT NO.4 above (Simmond J’s Jurisdictional Error).
3.3. Simmonds’ Juridictional Error would have
been corrected by the Evidence that was available before Commissioner Sleight
in CIV 1877 of 2010 which the former Judge had reference to. Despite the lack of evidence of fraud of
David Taylor, the former Judge would have made the findings of facts
made by Commissioner Sleight (Commissioner Sleight’s findings).
3.4. The Issues before Simmonds J,
Simmonds J’s Jurisdictional Error and Commissioner Sleights Findings when
complemented by the facts of the SINGLE ISSUE of the falsification of court
records by David Taylor would have found the Caveatable Interests of the New
Caveats for both the First and Second Applicants. If this were so, those
New Caveats would not have been removed by Simonds J on 12.8.2011 but for the
purported dishonesty of Mr. Chris Stokes as solicitor for the Administrator (the
Unjustified Removal of the New Caveats).
3.5. If Mr. Chris Stokes was fair and honest as
a court officer, he would not have misled Justice Simmonds and thereby
caused the Unjustified Removal of the New Caveats (the Purported Liability of
Mr. Chris Stokes).
4.
GROUNDS FOR THE ERRORS OF DCJ SWEENEY IN DCCIV2509 OF 2002:
4.1. The SINGLE ISSUE of the falsification of
court records by David Taylor caused the Default Judgment of DCJ Groves in
DCCIV 2509 of 2002 dated 10.10.2002 (the Default Judgment) to be left un-pursued
by David Taylor despite the former having been paid his legal fees for the same
purpose amounting to more than $60k by the Second Applicant (the Default of
David Taylor).
4.2. The Default of David Taylor amounted to a
criminal professional misconduct in that David Taylor was dishonest to the
Second Applicant under circumstances when he at all material times had received
legal fees and instructions from the Second Applicant since the initiation of
CIV 1142 of 2005 and CIV 1131 of 2006 together with the explicit instructions
to enforce the Default Judgment and he abandoned or neglected his duties as a
result (the Dishonesty of David Taylor).
4.3. The dishonesty of David Taylor caused
detriment and economic deprivations to both Applicants by obstructing justice:
he had caused prejudice to the legal practice of the First Applicant in VR87 of
2009 that has been heard before His Honour Judge Sharp of SAT on 11.10.2011 for
three days. Decision is being reserved for 90 days but an extension is being
granted for another 60 days. Murray
4.4. The
Default of David Taylor, the Dishonesty of David Taylor and the Effects of the
Dishonesty of David Taylor caused both the First and the Second Applicant to
co-operate with each other in concerted efforts to seek to prevent the
Injustices caused by the Jurisdictional Error of the Four Judges to achieve the
common purpose of vindicating their respective rights that is related to the SINGLE
ISSUE of the falsification of the court records (The Concerted Efforts to
Achieve Common Justice).
4.5. The Common Purpose of the First and Second
Applicants are to seek restitution from the administrator of the estate of
Nancy for the purpose of preventing the unlawful enrichment of the said estate
of Nancy so that justice must not only be done but must be seen to be done to
the creditors of the estate of Nancy who are the First and Second Applicants
respectively (the Restitution).
Dated the 7th day of February, 2012 .(Signed)
NICHOLAS NI KOK CHIN as the First Applicant
(Signed)
MAURICE FREDERICK LAW as the Second Applicant
I AGREE WITH THE JUDGEMENT OF THE LEARNED JUSTICE HEENAN IN http://decisions.justice.wa.gov.au/supreme/supdcsn.nsf/PDFJudgments-WebVw/2012WASC0208/$FILE/2012WASC0208.pdf
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