Business/Commercial Law Implied term Consumer Protection Prepared by tutor. Daniel Pan Implied terms Implied by common law Implied by statue Yeah!! (ACL) • Terms implied by common law – Implied by past dealing – Implied by trade custom • Con-Stan Industries of Australia Pty Ltd v Norwich Winterthur Insurance (Aust) Ltd – Implied by court • BP Refinery (Westernport) Pty Ltd v Hastings Shire Council – – – – – reasonable and equitable; necessary to give business efficacy to the contract; ‘it goes without saying’; capable of clear expression it must not contradict any express term in the contract. Consumer Contract • Terms implied by Statutory Law ACL – for “consumer contract only” !! –Sections 51-64 in ACL statutory guarantees • If a consumer contract in statutory meaning exist 1. A contract for supply of goods / services by A person – Natural person – Both individual / corporation 2. To Consumer • Provide for statutory guarantees (implied terms) for: ACL S.51 to S.64 What is a consumer contract ? A supply of goods/ service • By a legal person To CONSUMER! • s.3 definition Trade or commerce Terms implied • Terms implied: – statutory guarantee fog contract for sales of good : • • • • • • Ownership by seller s.51 Quiet procession by buyer s.52 Acceptable quality s.54 Fit for its purpose s.55 Corresponding quality and identity s.56 Corresponding to samples s.57 Terms implied • Terms implied: – statutory guarantee fog contract for sales of service : • Due care and skill s.60 • Reasonably fit for its purpose s.61 (1) • Nature / quality/ state /condition that they might reasonably be expected to achieve that result s 61(2) s.3 consumer S 3(1) if any one of the following criteria are met: 1. The amount payable for the goods does not exceed the prescribed amount (currently $40,000) or 2. The goods are of a kind ordinarily acquired for personal, domestic or household use or consumption (here no limit on the amount); or 3. The goods consisted of a vehicle or trailer acquired for use principally in the transport of goods on public roads (also here no limit on the amount). Page 9 s.3 consumer ? • S.3 (2) : main exception to S3(1) – However, s3 (1) does not apply when – Goods are acquired for resale / re-supply – Goods are acquired for reproduce / repair •Effect of exclusion clauses: • Any term implied by the ACL cannot be excluded, restricted or modified s 64 of the ACL – Any term that attempts to do so, is void • However, where the goods acquired are not of a type normally acquired for personal, domestic or household use, a seller is allowed under s 64A(1) and (2) – To limit its obligations to those of • Replacing • repairing or • repaying for the replacement or repair of the goods . Page 11 What if its not ? • NOT a consumer contract ? • Goods Act apply – How does it apply – What is the similarity ? – What is the different ? Goods Act 1958 Vic • Terms implied: – Implied term for contract for sales of good : • • • • Merchantable quality s.19(b) Fit for its purpose s.19(a) Corresponding description s.18 Corresponding to samples s.20 • Differences with ACL: – No provision for contract of services – Excludability (clear and précised) s.61 ACL: Consumer Protection Misleading s.18 Unconscionable Conduct s.20,21,22 Statutory Guarantee s.51 - s.64 Consumer Protection Manufacture's liability Misleading: s.18 The Australian Consumer Law contains a number of provisions that relate to misrepresentation. • Section 18: misleading and deceptive conduct; • A legal person • In trade or commerce • Should not engage in misleading / deceptive conduct 2Future Education Pty Ltd - All right reserved 15 Misleading: s.18 • Misleading conduct – Conduct is misleading when it lead the persons at whom it is directed into error. • McWilliam’s Wines Pty Ltd v McDonald's System of Australia Pty Ltd (1980) • Silence can be a form of misleading • Intention or negligence is irrelevant – Yorke v Treasureway Stores Pty Ltd (1983) • Action can be bought by all parties as long as the conduct is in breach of s.18 TERMS IMPLIED BY STATUTE Australian Consumer Law If Part 3-2, ACL applies to a particular consumer purchase then statutory obligations are imposed on the manufacturer. The statutory obligations imposed on the manufacturer relate to: 1) Fitness for Purpose: the consumer may take action against the manufacturer under s 271(1), ACL where a consumer guarantee under Pt 3-2 is not complied with eg not fit for purpose (s 54(2), ACL). 2) Description: action is available against the manufacturer under s 271(3), ACL where a consumer guarantee under Pt 3-2 is not complied with eg if the goods do not correspond with the description (s 56, ACL). 3) Merchantable Quality: 74D - the goods must be of merchantable quality 4) Sale by Sample: 74E - if the purchase is on the basis of samples then the goods supplied must correspond with the sample. Note: the manufacturer must compensate the consumer for loss or damage. Note: manufacturers are required to provide repairs or spare parts unless the consumer is made aware that these services will not be provided: s 58, ACL (former s 74F, TPA). MANUFACTURER’S LIABILITY FOR DEFFECTIVE GOODS Australian Consumer Law Part 3-5 The ACL Pt 3-5 (former TPA Pt VA) provides that a • manufacturer is liable for defective goods in circumstances where a person is injured or suffers property damage. • The injured party or the person suffering the loss does not have to prove negligence • merely that they suffered loss and that it was caused by the defective product. • Strict Liability d • The key elements of Pt 3-5 are: • • • • – s 7 : definition of manufacturer. – s 9 : defines “safety defect in relation to goods” as meaning “if their safety is not such as persons are entitled to expect” and lists relevant matters to take into account. s 138 ACL – allows a claim by ANY individual suffering loss as a result of injury. s 139 ACL : – loss as a third party S 140 ACL : – allows a claim for damage to other goods, however these other goods must be of a kind ‘ordinarily acquired for personal domestic or household use or consumption’. s 140 ACL bv – allows a claim for damage to land, buildings or fixtures (ordinarily acquired for private use). MANUFACTURER’S LIABILITY FOR DEFFECTIVE GOODS The manufacturer has recourse to defences set out in s 142, ACL (former s 75AK, TPA). These include: – the goods were not defective when the goods left the control of the manufacturer, – the goods complied with mandatory safety standards. A statutory defence of “contributory negligence” is also provided in s 137A, Competition and Consumer Act 2010 (Cth) (former s 75AN, TPA). Note: Exclusion clauses are void: s 150, ACL (former s 75AP, TPA) UNCONSCIONABLE CONDUCT • Unconscionable conduct refers to a pre-contractual situation in which one of the contracting parties has – superior bargaining power and the other party has some ‘special disability • Schroeder Music Publishing Co. Ltd. v Macaulay, Commercial Bank v Amadio, Louth v Diprose. • Statutory provision: Sections 20-22: – Sec. 20 (1) prohibited all unconscionable conduct in general law – Sec. 21 (1) specifically prohibited unconscionable conduct in supply of goods – Sec. 22 (1) specifically prohibited unconscionable conduct in supply / acquisition of goods (all business transaction) 2Future Education Pty Ltd - All right reserved • Extent the remedy to not only rescission but damages 21