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Do I Need Leave to Appeal to the Supreme Court?

It depends on two things: whether the judgment is final or interlocutory, and whether your grounds raise law, fact, or a mixture. Get either wrong and the appeal may be struck out as incompetent without the merits being reached.

The Supreme Court practice series, no. 11 · The right of appeal · 5 min read

This is the first question in every Supreme Court appeal, and the one most often answered wrongly. Two separate tests apply, and either can trigger the leave requirement.

Both questions must be asked

Test 1 — what kind of judgment?

Section 14(3)(b) of the Supreme Court Act: no appeal lies without leave from an interlocutory judgment, except where the liberty of the subject or the custody of infants is concerned; in cases of granting or refusing an injunction or appointing a receiver; or in such other cases prescribed by the Rules as are in the nature of final decisions.

Test 2 — what kind of ground?

Section 14(1): an appeal lies on a question of law or of mixed fact and law as of right; on a question of fact only with leave.

The tests are cumulative, not alternative

A ground of pure law still needs leave if the judgment is interlocutory and no exception applies.

A ground of fact still needs leave even from a final judgment.

So the safe question is not “is this final?” or “is this a point of law?” but both.

Working it through

Whether leave is required
JudgmentGroundLeave?
FinalLawNo — s 14(1)(a)
Mixed fact and lawNo — s 14(1)(b)
Fact aloneYes — s 14(1)(c)
InterlocutoryLawYes — s 14(3)(b)
Mixed fact and lawYes — s 14(3)(b)
Fact aloneYes — both limbs
Interlocutory, but within a s 14(3)(b) exception — liberty, custody of infants, injunction, receiverAs for a final judgment
Order extending time to appealYes — s 14(3)(a)
Order as to costs only, in the Court’s discretionYes — s 14(3)(c)
Order refusing unconditional leave to defendNo — deemed not interlocutory, s 14(4)
Consent orderNo appeal at all — s 14(2)

The interlocutory exceptions

Section 14(3)(b)(i)–(iii)

(i) Liberty of the subject or the custody of infants. Interlocutory orders touching a person’s liberty, or the custody of children, are appealable without leave.

(ii) Granting or refusing an injunction, or appointing a receiver. This is the most frequently used exception in commercial litigation. An interlocutory injunction — granted or refused — may be appealed as of right.

(iii) Such other cases prescribed by the Rules of Court as are in the nature of final decisions.

Why the injunction exception matters

An interlocutory injunction can decide the practical outcome of a dispute long before trial. Parliament recognised that by removing the leave requirement for that class of order.

The exception covers both granting and refusing. A plaintiff refused an injunction, and a defendant against whom one is granted, are equally within it.

On the principles the Court applies, see interim injunctions.

If your grounds are mixed

You may need two documents

In Yakham v Merriam [1997] PGSC 32; [1998] PNGLR 555 the Supreme Court held that where the grounds involve questions of law and/or mixed fact and law, the appeal lies as of right and a notice of appeal in Form 8 is filed under section 17 and Order 7 Rules 6 to 9.

Where the grounds involve only questions of fact, an application for leave in Form 7 is required under Order 7 Rules 1 and 2.

And where an appeal raises law, mixed fact and law, and fact, separate notices — Forms 7 and 8 — are required.

The Court also held that the then third alternative in paragraph 2 of Form 8, stating that leave was sought at the hearing of the appeal, was without legal basis and must be deleted, and overruled Opai Kunangel v The State [1985] PNGLR 144.

See filing separate notices.

Where the position is unclear

The prudent course

Where it is genuinely arguable whether leave is required, the conventional and safer course is to file both — an application for leave in Form 7 and a notice of appeal in Form 8 — within the 40 days.

Filing an unnecessary leave application costs little. Failing to file a necessary one is usually fatal, because by the time the point is taken the 40 days will have gone.

The respondent will take the point

Order 7 Rule 15 allows a respondent to object to competency within 14 days after service, in Form 9. Where an appeal has been brought without leave that was required, that is the objection that will be made.

Under Rule 18, the burden of establishing incompetency is on the party making the objection — but that is cold comfort if the appeal is in truth incompetent.

See objections to competency.

Leave is about the gateway, not the merits

What a grant of leave does and does not mean

Leave opens the door. It is not a finding that the appeal will succeed, and it does not bind the Court hearing the appeal.

Under Order 7 Rule 4, an application for leave must show that an appeal lies with leave and state the nature of the case, the questions involved and the reason why leave should be given. That is a threshold enquiry, directed at whether the matter is fit to be argued.

Once leave is granted, Order 7 Rule 6 requires a notice of appeal to be filed within 21 days after the date on which leave is granted, or within such further time as the Court or a Judge allows on application filed and served within those 21 days.

The 21 days is a separate trap

Obtaining leave is not the end of the timetable. A party who wins leave and then does nothing for a month will find the appeal itself out of time.

Note also that the notice of appeal must, under Order 7 Rule 9(a), state that leave has been granted and annex the appropriate order. See what the notice must contain.

Criminal cases

Section 22 has its own scheme

Conviction — no leave for a question of law alone or of mixed fact and law; leave (or a certificate of the National Court that it is a fit case for appeal) for a question of fact alone.

Sentencealways requires leave, and no appeal lies at all where the sentence is fixed by law.

See appealing a conviction and appealing a sentence.

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.