The Case Of Beck V. LW Furniture Consolidated Pty Ltd?

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The main issue with regards to the applicability of S1322(4)(a) to the appointment of Helen was the meaning of the word contravention. Statement of relevant facts: LW Furniture Consolidated Pty Ltd (“LWC”) was incorporated on 30 April 1971 by Leo Weinstock (“Leo”) and Hedy Weinstock (“Hedy”). On the 29 June 1973, LWC appointed Tamar Beck (“Tamar”) and Amiram Weinstock (“Amiram”) as directors (Weinstock, 22). Unbeknownst to Tamar and Amiram, their appointment as directors lapsed on the 31 December 1973. Tamar continued to act as director until her resignation on 8 January 1982, whilst Amiram continued as de facto director (Weinstock, 5). On 30 July 2003, Amiram appointed Mrs Helen Weinstock (Helen) as an additional director of LWC. The central issue of this case is whether Helen’s appointment as director is invalid, and whether the Court can overrule this irregularity. The primary judge, Barrett J found that the appointment of Helen was not invalid by reason of contravention of the company’s constitution (Beck v LW Furniture Consolidated (Aust) Pty Ltd (2011) NSWSC 235). This was overturned in the Court of Appeal by a majority of Young JA and Sackville AJA, who declared that Helen’s appointment was not a contravention, and therefore that section 1322(4) was not applicable (Beck v LW Furniture Consolidated (Aust) Pty Ltd (2012) NSWCA 76). Main issues Was Helen properly appointed as a director? It was found in the primary court that Helen was not properly appointed as a director of LWC (Beck v L W Furniture Consolidated (Aust) Pty Limited (2011) NSWSC 235). This was not disputed in the Court of Appeal or the High Court (Weinstock, 48). In reaching this decision, Barrett J considered multiple factors, including Amiram’s status an... ... middle of paper ... ... his actions were conducted in the best interest of the company. Further, by appointing Helen as director, no substantial injustice was done to any other parties. Thus, I am of the opinion that it is fair for s1322(4)(a) to apply in this situation. Further, I agree with statements made by French CJ that validating provisions are necessary because not all firms understand corporate governance, and that without these provisions, corporations would be vulnerable to simple errors (Weinstock, 39). As such, by declaring Helen’s appointment as not invalid by reason of contravention of the constitution, the court is acting in the best interests of all corporations and society in general. This decision allows businesses to function effectively, notwithstanding innocent or unsubstantial errors in corporate governance. Thus, I agree with the decision made by the High Court.

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