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What Is a Caveat in Probate?

A document lodged in the Registry by a person claiming an interest in an estate, which stops a grant or reseal being made without notice. It lasts six months unless the Court orders otherwise, and once one is in force the application for a grant must be commenced by writ of summons.

The National Court practice series, no. 221 · Probate and administration · 6 min read

Order 19 Division 10 of the National Court Rules 1983 provides for two kinds of caveat, which do different things.

Rules 60 and 61

Rule 60 — caveat in respect of grant, Form 95

(1) A person claiming to have an interest in an estate may lodge in the Registry a caveat in Form 95 in respect of any grant or reseal being made in the estate.

(2) It shall state fully the nature of the interest claimed by the caveator and an address for service.

(3) Where a person, to the knowledge of the caveator, is making or intending to make application for a grant or resealing, the caveator shall, within seven days of the lodging of the caveat, serve a copy of the caveat on him.

Rule 61 — caveat for solemn form, Form 96

(1) A person having an interest in an estate may lodge in the Registry a caveat in Form 96 requiring proof in solemn form of any will.

(2) and (3) impose the same requirements as to stating the interest and address for service, and as to service within seven days.

The two kinds of probate caveat compared
Caveat in respect of grant — Form 95Caveat for solemn form — Form 96
Who may lodgeA person claiming to have an interestA person having an interest
EffectStops a grant or reseal being made without noticeRequires proof in solemn form of any will
Use it whenYou dispute the applicant’s entitlement, or want notice before any grant issuesYou want the will proved properly — not merely accepted on the papers
CitationThe caveator shall … be cited to see the proceedings — r 67
Proof in solemn form

Proof in common form is what happens on an ordinary uncontested application: the will is proved on affidavit under Rule 24. Proof in solemn form means proving the will in contested proceedings, with the attesting witnesses available.

Rule 67: where there is in force a caveat requiring proof of a will in solemn form the caveator shall, in proceedings for a grant or for resealing in which the plaintiff seeks to prove a will to which the caveat relates, be cited to see the proceedings. See citations.

Rule 69

The application becomes contentious

(1) Where there is in force a caveat in respect of any grant or resealing being made in an estate, proceedings for a grant or for resealing in the estate shall be commenced by writ of summons.

(2) Unless the Court otherwise directs, the caveator shall be a party in the proceedings.

That is a substantial change

Without a caveat the application is a Division 3 matter: by summons in Form 70, heard in the absence of the public, without the appearance before the Court of any person, usually before the Registrar.

With a caveat it becomes a writ of summons proceeding with the caveator as a party — pleadings, and a hearing. That is why a caveat is an effective step, and why it should not be lodged without a real interest.

Rule 62

Six months

(1) A caveat shall take effect as of the date of lodgement and shall, unless the Court otherwise orders, remain in force for six months.

(2) The Court may extend the period of duration of a caveat.

Diarise the six months. A caveat that lapses leaves the estate open to a grant without notice.

Rule 68

Order that caveats cease to be in force

(1) A person intending to apply for a grant or resealing, faced with a caveat, may bring proceedings for an order that the caveat or each of the caveats, cease to be in force in respect of the intended application.

(2) The proceedings shall be commenced by originating summons.

(3) The caveator, or each of the caveators, shall be a defendant.

The test — sub-rule (4)

Where the Court considers that the evidence does not show

(a) that the caveator has an interest in the estate or has a reasonable prospect of establishing such an interest; and

(b) some matter occasioning doubts as to whether the grant ought to be made,

the Court may order that the caveat cease to be in force in respect of the intended application.

A caveator must be able to show both

An interest, or a reasonable prospect of establishing one — and some matter occasioning doubts as to whether the grant ought to be made. A caveat lodged out of general suspicion, without a stated interest and a stated doubt, is vulnerable.

That is also why Rules 60(2) and 61(2) require the caveat itself to state fully the nature of the interest. Draft it properly at the outset.

Note sub-rule (5): Order 12 Division 4 (summary disposal) does not apply to the proceedings. The caveat cannot be swept away by a summary judgment application.

Rules 63 to 66

Leave is required, and the route depends on the state of play

Rule 63 — where there are no proceedings for a grant or resealing: the application for leave shall be made by originating summons, there shall be no defendant, a draft minute of the order sought shall be lodged with the Registrar before any order is made, and the order shall be entered.

Rule 64 — where there are proceedings: if the caveator has not given notice of his intention to defend, he shall do so; and the application for leave shall be made by motion on notice in the proceedings.

Rule 65 — the caveator withdraws by writing in the margin of the caveat “I withdraw this caveat” and dating and signing the endorsement, and must within seven days serve notice of the withdrawal on any person who, to their knowledge, is applying or intending to apply.

Rule 66 — costs fall on the estate if the caveator cannot pay

Where a caveat is withdrawn and the applicant for the grant is unable to recover from the caveator costs which the caveator has been ordered to pay, that person shall be entitled to be recouped by the estate the amount of the costs properly incurred, in addition to other costs to which they are entitled out of the estate.

So an unmeritorious caveat ultimately costs the beneficiaries. That is a further reason for caution before lodging one.

Sources

The Wills, Probate and Administration Act 1966 is not available on PacLII.

Check the section yourself

Before relying on anything here, read the current text of the National Court Rules 1983 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.