14 December 2017

Bankruptcy: Fish Man v. Hadfield

Discharged from bankruptcy, Mark Richard Hadfield recovered ownership of his home against claims of unpaid creditors who argued they should get cash out of his Auckland home which had increased in value dramatically in the three years of his bankruptcy.
Mr Hadfield lives with his wife in Cameron Place, Ranui, west Auckland.  He was bankrupted in 2013 following liquidation of his failed tropical fish business: The Fish Man Ltd.  Mr Hadfield owed The Fish Man some $133,400 for funds the District Court ruled had been taken from his company.  On bankruptcy, the Insolvency Service took control of all Mr Hadfield’s assets, including his home.  It disclaimed any interest in his Cameron Place home.  There was no equity in the property.  The legal effect of Insolvency Service disclaiming land is that the bankrupt is no longer the owner; ownership passes to the Crown.  In fact, little happens.  As long as bankrupts keep up mortgage payments and pay rates, they stay living on the property as if they were still the owner.  The Insolvency Act requires court applications to sort out future ownership.
Mr Hadfield was discharged from bankruptcy in 2016.  One year prior, Fish Man liquidators applied to have the property sold, saying increases in Auckland property values meant there was now sufficient equity in Cameron Place to generate cash for repayment of Mr Hadfield’s debts.  Mr Hadfield applied to have Cameron Place re-vested in his name.  His wife claimed an interest in the property as relationship property; it was their family home, she had kept up mortgage payments both before and after her husband’s bankruptcy.
The Court of Appeal ruled it was too late for Fish Man liquidators to reverse the disclaimer and have Cameron Place sold.  Creditor objections to a disclaimer must be made within fifteen days.  They must also prove loss was suffered because of the disclaimer.  Objections cannot be raised years after the event, following an upsurge in property prices and with the benefit of hindsight, the Court said.
The Court of Appeal ruled Cameron Place was to be reregistered in the names of Mr and Mrs Hadfield.  Fish Man’s right to recover its $133,400 expired when Mr Hadfield was discharged from bankruptcy.  
The Fish Man Ltd v. Hadfield – Court of Appeal (14.12.17)

18.022