09 October 2015

Insolvency: Castlereagh Properties v. Walker

Water is becoming more valuable than gold in parched central Otago.  The Court of Appeal ruled a sale of Gibbston Valley’s water supply company for a nominal price of one dollar was invalid.  Company assets have a replacement value of some $158,000.   The deal was signed by Katrina Buxton, de facto wife of property developer David Henderson.
Gibbston Water Holdings Ltd is the corporate vehicle owning and operating a water reticulation system for the Valley with water rights, a pumping facility, a storage tank and 7.6 kilometres of pipes supplying about 30 properties.  It is a not-for-profit company with deed holders expected to meet operating costs.  Interest was piqued in August 2011 when control of the Gibbston Valley scheme passed to Castlereagh Properties Ltd, a company in David Henderson’s property group, at a cost of one dollar.  The paper work was signed by Ms Buxton.  The court was told this deal had the effect of taking Gibbston Water, and its water supply assets, out from under a mortgage otherwise secured over the water supply business.  Gibbston Water was promptly put into liquidation and liquidator Mr Robert Walker charged with the job of getting the water supply assets back from Castlereagh Properties.
The Court of Appeal ruled the liquidator had power to reverse the sale transaction since it was at an undervalue.  Ms Buxton argued her signature to the sale amounted to consent by the company to selling at an undervalue.  The Companies Act does allow “entitled persons” in a closely-held company to short-cut company procedures by their unanimous written consent.  The court ruled signing a contract of sale, by itself, cannot be read as written consent to bypass company law rules governing sales at an undervalue.
Castlereagh Properties v. Walker – Court of Appeal (9.10.15)

15.112