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Can I Appeal a Consent Order?

No. Section 14(2) of the Supreme Court Act provides that an appeal does not lie from an order of the National Court made by consent of the parties. The remedies lie elsewhere — an application below to set the order aside, or a review.

The Supreme Court practice series, no. 16 · The right of appeal · 5 min read

This is one of the few absolute bars in the Supreme Court Act. It is not a leave requirement that might be overcome — the right of appeal simply does not exist.

Section 14(2)

The provision

An appeal does not lie from an order of the National Court made by consent of the parties.

Supreme Court Act (Chapter 37)

Why

An appeal is a complaint that the court below went wrong. Where the order records what the parties themselves agreed, there is no judicial determination to attack. The order is, in substance, their contract, given the form of an order.

What is a consent order?

The essential feature

An order made by consent of the parties — one the parties asked the Court to make, or did not oppose on terms agreed between them.

Typical examples: orders giving effect to a settlement; agreed directions or timetables; orders by consent dismissing a proceeding; agreed orders as to costs.

Not every unopposed order is a consent order

There is a difference between an order the parties agreed to and one that was simply not opposed, or made in a party’s absence.

An order made because a party did not appear is not a consent order. Nor is an order made after argument in which a party made a concession on one point — the order still reflects the judge’s determination.

Where consent is disputed, the question is one of fact, and the record of the proceeding below will usually settle it.

Consent to part of an order

Where an order deals with several matters and the parties consented to some but not others, section 14(2) bars an appeal against the consented parts. The contested parts remain appealable in the ordinary way, subject to the usual questions about leave.

Order 7 Rule 9(b) requires the notice of appeal to state whether the whole or part only and what part of the judgment is appealed from — which is exactly the discipline needed here.

The first alternative — apply in the National Court

A consent order can be set aside, but not lightly

The court that made a consent order may set it aside on the grounds on which the underlying agreement could be impeached — principally fraud or mistake.

In Coecon Ltd v National Fisheries Authority [2002] PGNC 144; N2182 the National Court noted that consent judgments cannot be set aside easily except on appeal, or in fresh proceedings based on fraud or mistake — and that in consequence, where liability has been resolved by consent judgment, a defendant is not at liberty to take issue on any aspect of liability at the assessment of damages.

The application goes to the National Court, not the Supreme Court

Because no appeal lies, the Supreme Court is not the forum. The application to set aside is made in the court that made the order.

It is a substantive application requiring evidence of the vitiating factor — not a request to reconsider the merits of the bargain. A party who simply regrets a settlement has no remedy.

The second alternative — review

Constitution section 155(2)(b)

The Supreme Court has an inherent power to review all judicial acts of the National Court.

Where no appeal lies, that is the jurisdiction to consider. In Application by Herman Joseph Leahy [2006] PGSC 21; SC855 the Court held that a decision is reviewable under section 155(2)(b) where there is no right of appeal and no other way to bring the matter to the Supreme Court, provided the applicant shows an important point of law to be determined and that it is not without merit.

But review is not a way around section 14(2)

Review is available because no appeal lies — but the reason no appeal lies from a consent order is that the party agreed to it. That is not a promising foundation for arguing substantial injustice.

A review of a consent order would realistically need to be directed at something other than the merits of the bargain: for example, that the order was entered without the party’s authority, or that the Court lacked jurisdiction to make an order in those terms at all.

See section 155(2)(b) review.

Before you consent

Four points
  1. Consent is close to final. Section 14(2) removes the appeal, and setting aside requires fraud or mistake. Treat a consent order as the end of the matter.
  2. Get the terms right. An ambiguous consent order cannot be cured on appeal. Recall that in Bishop v Bishop Bros an ambiguous order could not found a contempt — precision at the drafting stage is what protects you.
  3. Confirm your authority. A lawyer consenting without instructions creates a serious problem for the client, and the remedy is not an appeal.
  4. Record what is not consented to. If part of the order is contested, make that clear on the face of the order, so the right of appeal against that part is preserved.
A related point on liability

Where liability is resolved by consent and damages are left to be assessed, Coecon confirms that the defendant cannot reopen liability at the assessment — but is not precluded from taking issue on any matter not pleaded in the statement of claim.

See assessment of damages.

Sources

Check the section yourself

Before relying on anything here, read the current text of the Supreme Court Rules 2012 and check for later amendments. If a decision matters to you, get advice — start with the Office of the Public Solicitor, or find a firm in the law firms directory.

Disclaimer: This article provides general information about Papua New Guinea law and does not constitute legal advice. Laws may change, and their application depends on individual circumstances. You should obtain professional legal advice for your specific situation. Read the full disclaimer.