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RE BANALASTA FARMING PTY LTD (ADMINISTRATORS APPOINTED) [2026] WASC 270

Case law · Western Australia · 2026
[2026] WASC 270 Page 1 JURISDICTION : SUPREME COURT OF WESTERN AUSTRALIA IN CHAMBERS CITATION : RE BANALASTA FARMING PTY LTD (ADMINISTRATORS APPOINTED) [2026] WASC 270 CORAM : LUNDBERG J HEARD : 30 JUNE 2026 DELIVERED : 2 JULY 2026 FILE NO/S : COR 58 of 2026 BETWEEN : CHANG JIA HENG TAI (HONG KONG) INVESTMENT LIMITED Plaintiff AND BANALASTA FARMING PTY LTD (ADMINISTRATORS APPOINTED) Defendant Catchwords: Corporations - Urgent applications by plaintiff creditor to appoint provisional liquidator or special purpose administrator to the defendant cattle farming business - Administrators recently appointed by sole director of defendant while plaintiff's winding up application pending - Winding up application based on failure to comply with a statutory demand - DOCA proposal advanced by director and related parties to be voted upon at looming second meeting of creditors - Relationship between winding up and administration processes - Turns on own facts -- 1 of 41 -- [2026] WASC 270 Page 2 Legislation: Corporations Act 2001 (Cth), s 435A, 440A, s 440D, s 447A, s 459A, s 459P, s 477 Result: Orders made for appointment of special purpose administrators. Category: B Representation: Counsel: Plaintiff : J P Cook Defendant : J S Slack-Smith Solicitors: Plaintiff : Mendelawitz Morton Commercial Lawyers Defendant : Dentons Australia Case(s) referred to in decision(s): Advance Housing Pty Ltd (in liq) v Newcastle Classic Developments (1994) 14 ACSR 230 Australian Securities and Investments Commission v Diploma Group Ltd [2017] FCA 549 Australian Securities and Investments Commission v Keystone Asset Management Ltd (recs and mgrs apptd) (admins apptd) (No 2) [2024] FCA 1040 [17] Deputy Commissioner of Taxation, in the matter of ACN 154 520 199 Pty Ltd (in liq) v ACN 154 520 199 (in liq) [2017] FCA 444 Grace v Grace [2007] NSWSC 6 Hughes v Receivers and Managers of Westgem Investments Pty Ltd (No 3) [2012] WASC 360 Hughes v Westgem Investments Pty Ltd (recs and mgrs apptd) (No 3) [2012] WASC 360 In the Matter of Pages Equipment Pty Ltd [2020] NSWSC 959 In the matter of Vietnam Industrial Investments Pty Ltd [2022] NSWSC 1411 -- 2 of 41 -- [2026] WASC 270 Page 3 Jahani, in the matter of Northern Energy Corporation Ltd (Administrators Appointed) (No 2) [2019] FCA 382 Lubavitch Mazal Pty Ltd v Yeshiva Properties No 1 Pty Ltd [2003] NSWSC 535; (2003) 47 ACSR 197 M2 Assets Pty Ltd v GT Capital Partners [2022] WASC 331 Re First Debenture Ltd [2015] NSWSC 1808 Re Grandview Ausbuilder Pty Ltd (admins apptd) [2019] NSWSC 1243 Re Offshore & Ocean Engineering Pty Ltd [2012] NSWSC 1296 Re Recycling Pty Ltd [2015] NSWSC; (2015) 107 ACSR 406 Sev.en Gamma a.s. v IG Power (Callide) Pty Ltd [2024] FCA 30; [2024] 172 ACSR 136 State of Victoria v CTM Training Solutions Pty Ltd (In Liq) & Ors [2017] VSC 47 -- 3 of 41 -- [2026] WASC 270 Page 4 Table of Contents Introduction ................................................................................................................................ 5 The plaintiff's interlocutory applications .................................................................................... 7 Appointment of provisional liquidators.................................................................................. 7 Special purpose administrators ............................................................................................. 10 Affidavit material and submissions ...................................................................................... 12 Factual background................................................................................................................... 13 The defendant's cattle farming business ............................................................................... 13 Loan of funds by the plaintiff ............................................................................................... 14 The appointment of administrators ....................................................................................... 15 Present assessments of the financial position of the defendant ............................................ 17 Investigations of voidable transactions and insolvent trading .............................................. 18 The DOCA Proposal ............................................................................................................. 22 Second meeting of the creditors ........................................................................................... 24 The positions of the parties ....................................................................................................... 24 The plaintiff's position .......................................................................................................... 24 The position of the present administrators ........................................................................... 26 Relevant principles ................................................................................................................... 27 Disposition ................................................................................................................................ 30 Conclusion and orders .............................................................................................................. 35 ATTACHMENT A Orders made on 30 June 2026 .................................................................. 37 ATTACHMENT B Orders made on 2 July 2026 ..................................................................... 38 -- 4 of 41 -- [2026] WASC 270 LUNDBERG J Page 5 LUNDBERG J: Introduction 1 The court has before it urgent applications which have been brought by the plaintiff creditor for the appointment to the defendant company of a provisional liquidator under s 472(2) of the Corporations Act 2001 (Cth) (CA), alternatively a special purpose administrator by exercising the plenary power in s 447A of the CA. 2 The defendant company operates a cattle farming business in New South Wales, to the north of Tamworth, trading as the Kia Ora Cattle Company. The financial position of the company is, and has been for some time, precarious and dependent on support from related entities. The plaintiff is an unsecured creditor of the defendant, having advanced substantial loan funds to the company some years ago, which it says were misapplied by the defendant and its sole director, Mr Huan Zhang. The transfer of these funds by the defendant to a related party, in a manner inconsistent with the express terms of the relevant loan agreement, together with the defendant's failure to repay the funds, due for repayment some years ago, are matters of serious and genuine concern to the plaintiff and its director, Mr Chung Fuk Chuk. 3 The present applications have been filed against the backdrop of pending winding up proceedings initiated by the plaintiff under pt 5.4 of the CA. A statutory demand had been served by the plaintiff, and not answered. The applications have also been filed in the wake of the recent appointment of administrators to the defendant by Mr Zhang, under the regime in pt 5.3A of the CA, with a looming second creditors' meeting having been scheduled to precede the hearing of the winding up application. The plaintiff says this was intended to thwart its winding up strategy. 4 This latter development, and the prospect of a proposal being put by the administrators at the creditors' meeting (which the administrators had recommended), was the immediate catalyst for the present applications, stinging the plaintiff into further action and prompting the request to the court late last week for the listing of an urgent hearing. 5 At its core, the plaintiff proposes that insolvency practitioners other than the present administrators should investigate and report on any offences by and claims against the sole director of the defendant, the claims against related parties of the defendant, and the -- 5 of 41 -- [2026] WASC 270 LUNDBERG J Page 6 recoverability of amounts from the director's personal assets and from the related parties. 6 The present administrators, Ms Jialan Xu and Mr Philip Campbell- Wilson of Grant Thornton, have opposed the relief sought. Through counsel, the administrators urged the court to adjourn the applications (and the winding up application itself) so as to permit the administrators more time to consider the factual issues raised by the plaintiff, which they say have now been more fully developed in the written submissions filed by the plaintiff on 29 June 2026, and to otherwise continue to discharge their statutory duties. 7 In answering this, the plaintiff contends that the administrators have failed to exercise the appropriate degree of independent rigour in order to properly understand and assess the strength, quantum and recoverability of claims which might be advanced by the defendant company against Mr Zhang and other related parties, including insolvent trading claims, preference payments, and breach of duty claims. 8 At the conclusion of the hearing on the afternoon of Tuesday, 30 June 2026, I reserved my decision on the applications to the afternoon of Thursday, 2 July 2026. To facilitate that occurring, in the exercise of the court's inherent discretion, I adjourned the winding up application, which had been listed for hearing on the morning of 2 July 2026. The court also noted the undertaking which had been proffered to the court by the administrators through counsel that they would not put to a vote a resolution under s 439C of the CA until Friday, 3 July 2026. 9 For the following reasons, I consider it is appropriate for the court to appoint special purpose administrators to the defendant, to undertake investigations concerning the affairs of the defendant as described in the minute of proposed orders drafted by the plaintiff. I will make orders accordingly. 10 It is appropriate to emphasise that the court has not concluded there is any conflict of interest between the present administrators and the defendant, or its sole director. Nor do these reasons include any finding of wrongdoing or breach of duty by those administrators. No such assertion was affirmatively put, although the plaintiff creditor certainly criticises the efforts of the present administrators. -- 6 of 41 -- [2026] WASC 270 LUNDBERG J Page 7 11 The approach the court has taken is driven by the evident need, in the interests of all creditors of the defendant, for a fulsome examination to be undertaken of the claims identified by the plaintiff, prior to any consideration of the future of the defendant company by those creditors, leaving the present administrators to continue their management of the defendant's business. The plaintiff's interlocutory applications 12 I will first outline the scope of the application filed by the plaintiff before setting out the salient background facts and context to these matters. 13 On Friday, 26 June 2026, the plaintiff filed an interlocutory process by which it sought urgent orders for the appointment of a provisional liquidator to the defendant under s 472(2) of the CA, alternatively for the appointment of a special purpose administrator by exercising the power in s 447A of the CA. 14 The interlocutory process was listed for hearing on 30 June 2026 on the request of the plaintiff, so as to precede the second creditors' meeting which had been scheduled for 1 July 2026. Appointment of provisional liquidators 15 The plaintiff, in the first instance, seeks an order that Mr Mathieu Tribut and Mr Mitchell Warren Ball, of Mackay Goodwin, be appointed as joint and several provisional liquidators of the defendant. Allied to that, the plaintiff seeks an order that the administration of the defendant be terminated forthwith, pursuant to s 447A of the CA and s 90-15 of the Insolvency Practice Schedule to the CA (IPS). 16 Section 472 of the CA provides as follows: 472 Court to appoint registered liquidator (1) On an order being made for the winding up of a company, the Court may appoint a registered liquidator to be liquidator of the company. (2) The Court may appoint a registered liquidator provisionally at any time after the filing of a winding up application and before the making of a winding up order or, if there is an appeal against a winding up order, before a decision in the appeal is made. (3) A liquidator appointed provisionally has or may exercise such functions and powers: -- 7 of 41 -- [2026] WASC 270 LUNDBERG J Page 8 (a) as are conferred on him or her by this Act or by rules of the Court that appointed him or her; or (b) as the Court specifies in the order appointing him or her. (4) A liquidator of a company appointed provisionally also has: (a) power to carry on the company's business; and (b) the powers that a liquidator of the company would have under paragraph 477(1)(d), subsection 477(2) (except paragraph 477(2)(m)) and subsection 477(3) if the company were being wound up in insolvency or by the Court. (5) Subsections 477(2A) and (2B) apply in relation to a company's provisional liquidator, with such modifications (if any) as the circumstances require, as if he or she were a liquidator appointed for the purposes of a winding up in insolvency or by the Court. (6) If more than one liquidator is appointed by the Court, the Court must declare whether anything that is required or authorised by this Act to be done by the liquidator is to be done by all or any one or more of the persons appointed. 17 The terms of s 440A of the CA are particularly relevant to the determination of the present applications. Section 440A provides: 440A Winding up company (1) A company under administration cannot be wound up voluntarily, except as provided by section 446A or 446AA. (2) The Court is to adjourn the hearing of an application for an order to wind up a company if the company is under administration and the Court is satisfied that it is in the interests of the company's creditors for the company to continue under administration rather than be wound up. (3) The Court is not to appoint a provisional liquidator of a company if the company is under administration and the Court is satisfied that it is in the interests of the company's creditors for the company to continue under administration rather than have a provisional liquidator appointed. 18 The orders proposed by the plaintiff contemplate that the provisional liquidators be empowered to carry out a range of specified functions. The specified functions are as follows: -- 8 of 41 -- [2026] WASC 270 LUNDBERG J Page 9 1. The Provisional Liquidators shall, within 28 days of this Order, provide to the Court and to the parties, a report as to the provisional liquidation of the Defendant (“Report”), including: (i) the identification of the assets and liabilities of the Defendant; (ii) an opinion as to the solvency and date of insolvency of the Defendant; (iii) an opinion as to the value of the assets of the Defendant; (iv) an opinion as to the likely return to creditors and shareholders, if the Defendant is wound up; (v) an opinion as to whether the Defendant has proper financial records; (vi) any other information necessary to enable the financial position of the Defendant to be assessed; (vii) any suspected contraventions of the Act by the Defendant; (viii) any suspected contraventions of the Act by the director of the Defendant; (ix) offences by and claims against the director of the Defendant; (x) claims against related parties of the Defendant; (xi) claims against any other parties; (xii) recoverability from the director's personal assets; and (xiii) recoverability from related parties of the Defendant. 2. Investigate and report upon the appropriateness of making an application for, and conducting, examinations under ss 596A and 596B of the Act and orders for production pursuant to s 579(9), for the purposes of the investigations referred to herein. 3. Consider the claims available to the Defendant in relation to the matters arising from the investigations and examinations referred to in this Annexure, and from examination of the books and records of the Defendant, including obtaining and considering legal advice in respect of any such claims. -- 9 of 41 -- [2026] WASC 270 LUNDBERG J Page 10 4. Undertake such further or other matters in relation to the affairs of the Defendant as the Court considers appropriate and so orders. 19 Further, the plaintiff proposes that the provisional liquidators be entitled to exercise, for the purposes of facilitating the functions specified in the proposed orders, all the powers conferred on a liquidator by s 477 and div 2 of pt 5.4B of the CA. An order is also sought by which the defendant would be obliged to cooperate and provide all reasonable assistance required of it by the provisional liquidators, including making available to the provisional liquidators all books and records of the defendant. Special purpose administrators 20 In the alternative, the plaintiff seeks an order pursuant to s 477A and s 451A(2) of the CA that Mr Tribut and Mr Goodwin be appointed as additional joint and several administrators of the defendant. The plaintiff proposes to provide the initial funding for this appointment. 21 The plaintiff proposes that the special purpose administrators investigate and report on any offences by and claims against the director of the defendant, claims against related parties of the defendant, recoverability from the director's personal assets, and recoverability from related parties of the defendant. 22 An order is sought that, pursuant to s 447A of the CA, the special purpose administrators be empowered to carry out the following functions: 1. Conduct investigations into, and within 28 days of this Order, provide to the Court and to the parties, a report as to the following matters (“Report”): (i) the identification of the assets and liabilities of the Defendant (ii) an opinion as to the solvency and date of insolvency of the Defendant (iii) an opinion as to the value of the assets of the Defendant (iv) an opinion as to the likely return to creditors and shareholders, if the Defendant is wound up (v) an opinion as to whether the Defendant has proper financial records -- 10 of 41 -- [2026] WASC 270 LUNDBERG J Page 11 (vi) any other information necessary to enable the financial position of the Defendant to be assessed (vii) any suspected contraventions of the Act by the Defendant (viii) any suspected contraventions of the Act by the director of the Defendant (ix) offences by and claims against the director of the Defendant (x) claims against related parties of the Defendant (xi) claims against any other parties (xii) recoverability from the director's personal assets (xiii) recoverability from related parties of the Defendant. 2. Investigate and report upon the appropriateness of making an application for, and conducting, examinations under ss 596A and 596B of the Act and orders for production pursuant to s 579(9), for the purposes of the investigations referred to herein. 3. Give consideration to the claims available to the Defendant (or its administrator) in relation to the matters arising from the investigations and examinations referred to in this Annexure, and from examination of the books and records of the Defendant, including obtaining and considering legal advice in respect of any such claims. 4. Take possession of such books and records of the Defendant as the Special Purpose Administrators deem necessary for the purpose of the investigations and examinations referred to herein, subject to the proviso that the Special Purpose Administrators will provide the Primary Administrators all reasonable access to those books and records and the Primary Administrators are permitted to make such copies of them as they see fit. 5. Undertake such further or other matters in relation to the administration and affairs of the Defendant as the Court considers appropriate and so orders. This includes, for the avoidance of doubt, making an application to extend the administration of the Defendant. 6. Make an application pursuant to ss 442A and/or 447A of the Act, and/or s 90-15 of Sch 2 to the Act, that they be justified in executing, on their own behalf as Special Purpose -- 11 of 41 -- [2026] WASC 270 LUNDBERG J Page 12 Administrators and on behalf of the Defendant, a funding and indemnity deed. 23 Further, the plaintiff seeks orders to the effect that the special purpose administrators be entitled to exercise, solely for the purposes of carrying out the above functions, all the powers conferred on an administrator by s 437A and div 8 of pt 5.3A of the CA. 24 As to the continuing role of the present administrators, the plaintiff seeks an order, pursuant to s 447A of the CA, that the administrators refrain from exercising any of the powers of the special purpose administrators, except with the prior written consent of the special purpose administrators or by leave of the court. 25 The plaintiff seeks an order that the present administrators must use their reasonable endeavours to assist the special purpose administrators to exercise the powers given to them by the proposed orders, including by providing documents or information previously prepared or obtained by them in investigating or pursing any claim in relation to the matters set out in the plaintiff's orders. The present administrators would also be precluded from holding a vote at the second meeting of creditors to resolve that the defendant execute a deed of company arrangement, until after the special purpose administrators have reported to them. 26 Importantly, the plaintiff says, it seeks an order that, pursuant to s 447A of the CA, the indemnity provisions in s 443D to s 443F of the legislation would not apply in the appointment of the special purpose administrators such that they would not be entitled to be indemnified out of the defendant's property, nor would they have a lien over the defendant's property. Affidavit material and submissions 27 The court has been presented with detailed affidavit material from the plaintiff and from the administrators, which I will describe in due course. 28 For its part, the plaintiff relies on the affidavit sworn by its solicitor on 26 June 2026 (the Cook Affidavit). In that affidavit, Mr Cook largely produces documentary material evidencing the plaintiff's loan agreement, communications between the law firms and the administrators, and a copy of the detailed reports prepared by the -- 12 of 41 -- [2026] WASC 270 LUNDBERG J Page 13 administrators which is dated 23 June 2026.1 I will refer to that report as the Administrators' Report. Both counsel drew heavily on that report at the hearing of the applications. 29 For the administrators, a comprehensive affidavit was sworn by one of the administrators, Ms Xu. I refer to her affidavit sworn on 30 June 2026 (the Xu Affidavit). Within that affidavit, Ms Xu has explained, in some detail, the steps the administrators have taken to assess and manage the business of the defendant and to undertake the administration process in accordance with their obligations.2 30 The court also received detailed written submissions from both the plaintiff and from the administrators, filed on 29 and 30 June 2026 respectively, which both counsel amplified at the hearing on 30 June 2026. Factual background 31 The following factual matters are drawn from the Cook Affidavit and the Xu Affidavit, and particularly from the Administrators' Report. There are factual matters which remain contentious and it is not intended in these reasons to resolve those matters, not is it necessary for the purposes of resolving the present disputes. The defendant's cattle farming business 32 The defendant company operates a cattle farming business in New South Wales, on around 6,100 hectares in Bendemeer, which is an area to the north of Tamworth. It trades as the Kia Ora Cattle Company. The land on which it operates is known as the Kia Ora Aggregation, comprising the historical farming properties of Birralee, Burlington, and part of Banalasta. The farmland itself is owned by a related company (BK Farms Holding Pty Ltd) and leased to the defendant. 33 Mr Huan Zhang is the sole director of the defendant company and holds 50% of the shares in the entity, the other shareholder being JBN Agricultural Group Pty Ltd. The defendant's business operates through a complex corporate structure involving several trusts and related companies, with Mr Zhang at the centre of the enterprise. 1 Cook Affidavit, Attachment JPC 12. 2 Xu Affidavit. -- 13 of 41 -- [2026] WASC 270 LUNDBERG J Page 14 34 At the time of the appointment of administrators, the defendant employed a total of eight full time employees and one casual employee. These persons include Mr Zhang and two of his relatives. Loan of funds by the plaintiff 35 In November 2019, the defendant borrowed $3.0 million from the plaintiff, which was advanced by way of three equal tranches of $1.0 million each. A written loan agreement is in existence, prepared in Mandarin, but a translated copy has been produced to the court.3 36 These funds were advanced for the express purpose of purchasing cattle. On the presently available material, the defendant appears not to have discharged that purpose. Instead, within three days of receipt, it transferred the funds to a related company, Australia QC Holding Pty Ltd. That related company presently owes the defendant company some $2.3 million, which the plaintiff says is the 'direct product of the use' of the funds loaned by the plaintiff.4 37 This transfer of funds in a manner inconsistent with the loan agreement, coupled with the defendant's failure to repay the loaned funds, which were due for repayment some years ago, are matters of concern to the plaintiff. 38 Indeed, the plaintiff has been pursuing the loaned funds through several avenues. First, in early February 2026, the plaintiff initiated recovery proceedings against the defendant in this court.5 With interest, the plaintiff calculates its total claim against the defendant to be around $4.139 million. 39 Second, in late February, the plaintiff served a statutory demand on the defendant pursuant to s 459E of CA. That was served on around 24 February 2026. The statutory demand is dated 12 February 2026. It was accompanied by an affidavit sworn by Mr Chung Fuk Chuk dated 12 February 2026. The statutory demand expired on 17 March 2026. It went unanswered. 40 Third, in May 2026, the plaintiff filed a winding up application under div 4 pt 5.4 of CA on the basis that the defendant failed to answer the statutory demand which had been served.6 The proceeding was 3 Loan agreement dated 15 November 2019; Cook Affidavit, Attachment JPC 1. 4 PS [3]. 5 Supreme Court CIV 1148 of 2026. 6 COR 58 of 2026. -- 14 of 41 -- [2026] WASC 270 LUNDBERG J Page 15 filed on 19 May 2026. The plaintiff's winding up application had been listed for hearing for the morning of 2 July 2026 before the Acting Master. 41 For its part, the defendant brought proceedings in the Federal Court of Australia to set aside the statutory demand which had been served, asserting a genuine dispute. It appears the plaintiff contested the application, and the defendant ultimately consented to the dismissal of the application and agreed to pay the plaintiff's costs.7 There is a suggestion in the materials, which appears to have substance, that the application to set aside the demand was filed out of time. 42 There are two features of the plaintiff's claim against the defendant which struck me on first review. I have mentioned both of them below but, as explained, they can be put to one side for now. 43 The first is the lapse of time since the funds were advanced and the potential that the applicable limitation period had expired. Counsel for the plaintiff points to, at least, certain acknowledgements of debt in this regard as an antidote to any such concern. 44 The second feature is whether the plaintiff has a viable claim for contractual interest. I can put this issue to one side for now given the statutory claim for interest available to the plaintiff, which would be sizeable given the lapse of time since the loan was due and payable. The appointment of administrators 45 Subsequent to the filing of the present proceedings by the plaintiff, the sole director of the defendant appointed administrators to the company, under the provisions of pt 5.3A of the CA. He did that on 8 June 2026. As earlier noted, the appointed administrators are Ms Jialan Xu and Mr Philip Campbell-Wilson of Grant Thornton. 46 Section 435A of the CA identifies the objects of pt 5.3A in the following terms: 435A Object of Part The object of this Part, and Schedule 2 to the extent that it relates to this Part, is to provide for the business, property and affairs of an insolvent company to be administered in a way that: 7 I refer to the consent orders made by the Federal Court of Australia on 29 April 2026. -- 15 of 41 -- [2026] WASC 270 LUNDBERG J Page 16 (a) maximises the chances of the company, or as much as possible of its business, continuing in existence; or (b) if it is not possible for the company or its business to continue in existence -- results in a better return for the company's creditors and members than would result from an immediate winding up of the company. 47 The administration process has moved swiftly following the appointment of the present administrators. The plaintiff observes that the 'haste and timing' of the administration process is 'difficult to understand',8 while the defendant explains, in a matter-of-fact way, that administration under pt 5.3A is typically a 'rapid process'.9 48 Counsel for the administrators has submitted that:10 …the Administrators have identified substantial risks in dealing with the Company's only substantial asset being a living herd of cattle, including in respect of statutory animal welfare obligations and operational risks as to weather, feed availability and veterinary contingencies, with these issues exacerbated in circumstances where 500 head of cattle are in late-stage pregnancy. … The Administrators have progressed the administration in a swift and practical manner due to the serious potential animal welfare concerns… 49 The plaintiff disputes the existence of any animal welfare concern, explaining that:11 The 500 heavily pregnant cattle are soon to perform their most significant value-adding function, by doubling the number of the remaining herd with their progeny. That is the obviously profitable phase of the process of running a herd. 50 The administrators have explained on affidavit, in some detail, the steps they have taken to assess and manage the business of the defendant and to undertake the administration process in accordance with their obligations.12 51 Following the assessment of the company's ability to continue trading, the administrators ultimately determined that trading should 8 PS [68]. 9 DS [5]. 10 DS [15.2] and [24]. 11 PS [43]. 12 Affidavit of Jialan Xu sworn 30 June 2026. -- 16 of 41 -- [2026] WASC 270 LUNDBERG J Page 17 continue on a controlled basis to preserve the value of livestock assets and facilitate an orderly realisation strategy. The administrators have indicated they will continue to manage the trading activities prudently to maximise available returns to creditors during the administration. 52 It is also evident that certain related parties of the defendant have provided the administrators with indemnities in respect of the administration. Specifically, an upfront cash indemnity of $400,000 has been provided, together with a further indemnity of up to $600,000 (together with certain costs). The source of the indemnity has been BK Farms Holding Pty Ltd, BK Farms Holding Unit Trust, Australia QC Holding Pty Ltd, and Australia QC Holding Family Trust — all of which are connected to Mr Zhang. 53 The first meeting of creditors of the defendant was held on 17 June 2026, but it appears nothing of consequence occurred at the meeting. I note the administrators were not replaced and no Committee of Inspection was appointed. Present assessments of the financial position of the defendant 54 The Administrators' Report presents a bleak picture of the financial position of the defendant and its business, although the court recognises that the administrators have not undertaken an audit of the company's affairs and their work has been undertaken in a swift manner. 55 Stated shortly, the financial position of the company is presently precarious and dependent on support from related entities. That has been the position for some time. 56 The present administrators opined that the defendant's descent into voluntary administration arose from a combination of factors. The defendant experienced a 'sustained deterioration in its cashflow position and a history of unprofitable trading over an extended period, which eroded its capital base'.13 Further, the operations of the company 'had been heavily reliant on financial support from related parties, and the withdrawal or curtailment of that support removed a key source of working capital'.14 57 Further to this, the administrators observed that the company's business 'appears to have been substantially reliant on ongoing funding 13 Administrators' Report p 16. 14 Administrators' Report p 16. -- 17 of 41 -- [2026] WASC 270 LUNDBERG J Page 18 from related parties, particularly during its formative years, with limited evidence of sufficient external cash inflows to support its working capital requirements independently of such support'.15 58 The administrators describe the existence of a pattern of 'circular funding' between related parties.16 59 The administrators noted there were several secured creditors with interests over the property of the defendant. One of those secured creditors holds a $4.0 million agricultural commodities finance facility which was put in place some six months prior to the appointment of the administrators. At the time of their appointment, the secured creditor had advised that the quantum of debt outstanding under the facility was around $2.5 million. The secured creditor's security comprises specific security interests in respect of the company's livestock and a blanket security interest over the remainder of the company's assets.17 60 The administrators investigations of the financial statements and performance of the defendant revealed that the company incurred cumulative net losses of around $8.3 million between the 2023 financial year and the present. The trading losses had reduced in the 2025 financial year and in the present financial year, but the administrators suggested that the 'improved performance is likely overstated due to non-payment of lease obligations, reducing reported expenses and overstating the Company's overall financial performance'.18 61 In a similar vein, the administrators indicated in their report that the balance sheet of the company 'reflects a deteriorating financial position, characterised by increasing liabilities, reliance on related party funding, and a declining net asset position'.19 62 In its submissions, the plaintiff refers to the 'unwavering losses' of the defendant as totalling around $11.0 million since 2020, through to the appointment of the administrators on 8 June 2026.20 Investigations of voidable transactions and insolvent trading 63 The Administrators' Report includes a summary of their investigations in relation to potential offences, voidable transactions 15 Administrators' Report p 17. 16 Administrators' Report p 17. 17 Administrators' Report p 20. 18 Administrators' Report p 23. 19 Administrators' Report p 24. 20 PS [16]. -- 18 of 41 -- [2026] WASC 270 LUNDBERG J Page 19 and insolvent trading in relation to the defendant.21 The report also addresses the sole director's personal financial position.22 The plaintiff makes some criticism of the approach which has been adopted in this regard. 64 The preliminary investigations of the administrators have revealed that the sole director may have breached s 180, s 181, and s 182 of the CA, and may also have permitted the company to engage in insolvent trading in contravention of s 588G of the CA, in connection with the use of loan funds received from the plaintiff.23 The administrators point to the funds advanced by the plaintiff which were promptly then transferred to a related company. The administrators note that, should the defendant be placed into liquidation, further investigations would be undertaken in relation to these matters. 65 There are also potential and viable unfair preference claims which have been identified by the administrators. These claims concern third parties and related parties. The recoverability of the claims is limited, according to present investigations.24 66 As to the present assessment of the insolvency of the defendant, the administrators concluded:25 … it is our opinion that the Company was insolvent upon failing to comply with the statutory demand, which expired on 17 March 2026. From that time, the Company appears to have had limited ability to obtain further funding to meet its liabilities as and when they became due and payable. Conclusion on the Cash Flow Test of Insolvency • On the basis of our review of the Company's ability to pay its debts as and when they fall due, it appears the Company has been predominantly supported by funding from related entities. Nonetheless, the quantum of aged payables began to significantly increase around March 2026, which is indicative of difficulties in obtaining support from alternative sources of funding. • Subject to overall capacity of the related parties to provide funding, to the Company, the Company may not have had 21 Administrators' Report pp 35 - 52 22 Administrators' Report p 53. 23 Administrators' Report p 36. 24 Administrators' Report p 49. 25 Administrators' Report p 44. -- 19 of 41 -- [2026] WASC 270 LUNDBERG J Page 20 sufficient funding available to meet the repayment of the Petitioning Creditor's debt from 10 February 2020. • We have requested information from the related parties to determine the financial capacity and willingness of these entities to support the Company's historical and ongoing obligations and have not received a response at this time. 67 Building on the foregoing, the administrators concluded that:26 Following a preliminary review of the indicators of insolvency in both the balance sheet and cash flow tests, we are of the opinion that the Company became insolvent on or around 17 March 2026 as a consequence of the failure to comply with the statutory demand served by the Petitioning Creditor. Subject to the willingness and capacity of the related parties to provide support and funding to the Company, the Company may have been insolvent from as early as 11 February 2020. Should the Company be placed into liquidation, further investigations will be undertaken in this regard. 68 The plaintiff criticises the efforts of the administrators to properly assess the financial position of the sole director of the defendant. The administrators have expressed opinions in this regard, but it is apparent the sole director has been less than forthcoming in answering their queries. 69 The administrators note the following matters in their report:27 Our preliminary investigations indicate that if the Company was wound up, a liquidator may have potential claims against the Director for insolvent trading up [to] a maximum amount of c. $1.3m and potential unreasonable director related transactions of c. $370k. The quantum of these claims is subject to change as further investigations are carried out. The commerciality of pursuing any potential claims against the Director is subject to their financial capacity to meet a judgment made against them. Following our appointment, we requested the Director provide a statutory declaration outlining their respective personal asset and liability positions. To date, we have yet to be provided with same. However, the Director has claimed that he has no significant personal Australian-based assets. 26 Administrators' Report p 44. 27 Administrators' Report p 53. -- 20 of 41 -- [2026] WASC 270 LUNDBERG J Page 21 We have carried out real property searches in NSW in the name of the Director to determine if they hold any freehold assets in their name. The search identified twenty-one (21) properties registered in the name 'Huan Zhang'. Given that this is a popular name, it is unclear how many of these properties (if any) are owned by the Director. A search of the ASIC database in the Director's name has also identified several other potential shareholdings in entities outside of the group structure set out in Section 3 of this report (as set out in the table opposite). Similar to our comments above, it is unclear whether these shareholding all relate specifically to the Director. We are also unaware of whether any of these shareholdings have any significant value at this time. At this stage, the Administrators have not received any evidence or statement from the Director regarding any assets held in another jurisdiction. … As such, it is unclear whether the Director has any capacity from onshore assets to meet any judgment which may be awarded against them. The Administrators have not, to date, undertaken a detailed investigation of the Director's asset position, whether onshore or offshore. Should the Company be placed into liquidation, further investigation into the Director's financial capacity [sic - would be undertaken]. The Administrators' present view, however, is that even if a liquidator were to obtain judgment against the Director in respect of an insolvent trading or other claim, there is a material risk that the practical recoverability of that judgment would be limited, particularly to the extent the Director's asset base is concentrated offshore. 70 In contrast, the plaintiff submits that the entirety of the asset pool reflected in the overall corporate group structure must be examined.28 71 The plaintiff points to the freehold of the farm upon which the company operates its herd, which is held by a related company. The plaintiff submits there is strong evidence in the report that the true insolvent trading claim is for no less than $11.0 million and that Mr Zhang has substantial assets in his corporate group, notwithstanding his refusal to provide information. Further, the plaintiff suggests there is a 'potential preference payment' to another related company owned and controlled by Mr Zhang in the amount of $2.46 million, which was made during 2024. 28 PS [34]. -- 21 of 41 -- [2026] WASC 270 LUNDBERG J Page 22 The DOCA Proposal 72 Within the Administrators' Report, the administrators recommended that creditors vote in favour of a Deed of Company Arrangement (DOCA Proposal) proposed by Mr Zhang and certain related parties. 73 The DOCA Proposal was received on 23 June 2026 from BK Farms Holding Pty Ltd in its own capacity and as trustee for BK Farms Holding Unit Trust, and from Australia QC Holding Pty Ltd in its own capacity and as trustee for Australia QC Holding Family Trust. 74 It is not necessary to detail all of the specifics of the DOCA Proposal. In summary, drawing from the details included in the Administrators' Report which has been circulated to creditors, the DOCA Proposal provides as follows: (a) First, it provides for a deed fund to be established comprised of any funds held by the administrators at the time of execution of the DOCA, any receivables recovered from the defendant's debtors as at the date of appointment, or any debtors arising from trading during the administration period, the upfront indemnity funds of $400,000 held in the Grant Thornton trust account will be a contribution into the deed fund, and a contribution of $1.2 million which will arise from the sale proceeds of the defendant's cattle inventory in early 2027. (b) Second, to ensure the performance of the DOCA and for the defendant to commit the sale proceeds of the cattle to the deed fund, various actions will be undertaken. These actions include the administrators registering a security interest against all of the assets of Australia QC, BK Farms will commence a refinance of the secured creditor debt, effectively paying out the defendant's liability and BK Farms will have a subrogated claim against the defendant. Further, BK Farms will enter into a side deed permitting the defendant to attend to the sale of the secured cattle and commit the sale proceeds to the deed fund. Additionally, the proponents will guarantee a floor of $1.2 million in respect of the contribution to the deed fund from the sale proceeds of the defendant's cattle (such that if the cattle proceeds do not achieve a deed fund contribution of $1.2m, the proponents will make a cash contribution for any shortfall amount so as to ensure at least $1.2m is contributed to the deed fund). Once the deed fund is constituted and distributed to -- 22 of 41 -- [2026] WASC 270 LUNDBERG J Page 23 creditors, the defendant's Australia QC loan receivable will be assigned to BK Farms as consideration for BK Farms refinancing the secured creditor and procuring the release of the subrogated debt and security, and the security interest against Australia QC will be discharged. (c) Third, the DOCA will contain a clause that will allow (but not require) the proponents to make a cash contribution of $1.2m (equivalent to the minimum amount proposed for the deed fund contributions from the defendant's cattle). This would have the effect of expediting the return to creditors under the DOCA. (d) Fourth, the deed fund will then be distributed in accordance with the following process and priority: (i) First, in respect of any outstanding remuneration and costs properly incurred by the administrators (ii) Second, in respect of any outstanding remuneration and costs properly incurred by the deed administrators; (iii) Third, to pay in full the admissible claims of any priority employee creditors; (iv) Fourth, to pay, on a pari passu basis, the ordinary unsecured creditors of the company in respect of their admitted claims; and (v) Lastly, any remaining balance thereafter to the company. (e) Fifth, the balance of the assets of the defendant will not be available for realisation to augment the deed fund and will be retained by the defendant to facilitate ongoing business operations. (f) Sixth, related party creditor claims will be deferred and will not participate in any distribution in the DOCA. That said, the related party creditors will remain eligible to participate in the DOCA for their priority employee entitlements up to the statutory maximums set out in section 556 of the Act. 75 As noted above, the DOCA Proposal provides that related party creditor claims would be deferred and they will not participate in any distribution in the DOCA. -- 23 of 41 -- [2026] WASC 270 LUNDBERG J Page 24 76 In terms of the estimated return to creditors in the competing scenarios, the administrators prepared an estimated income statement, which is extracted below.29 This statement formed part of the Administrators' Report. 77 As is evident from the above statement, the administrators have estimated that, in a liquidation scenario, recoveries are uncertain, dependent on successful litigation outcomes on voidable transaction and insolvent trading claims, and the realisation of related party receivables. In contrast, in a DOCA scenario, unsecured creditors are estimated to receive approximately 25 to 35 cents in the dollar, with distribution within around twelve months. Second meeting of the creditors 78 A second meeting of the creditors of the defendant was to be held on Wednesday, 1 July 2026, as part of the administration process. At that meeting, the creditors were due to vote on the DOCA Proposal. 79 More specifically, the creditors of the defendant (including the plaintiff) would have voted on whether the DOCA Proposal should be approved, whether the company should be wound up, or whether the company should be returned to the control of its director. The positions of the parties The plaintiff's position 80 For its part, the plaintiff emphasises that the administrators have failed to exercise the appropriate degree of muscle and independent rigour in order to properly understand and assess the strength, quantum and recoverability of claims which might be advanced by the defendant company against Mr Zhang and other related parties, including 29 Administrators' Report p 59. -- 24 of 41 -- [2026] WASC 270 LUNDBERG J Page 25 insolvent trading claims, preference payments, and breach of duty claims. 81 Assertions of a lack of independence on the part of the administrators permeate the submissions filed by the plaintiff. The plaintiff says it is 'so sceptical' of the approach adopted by the present administrators, that it is 'inevitable' that it would challenge any resolution in favour of the DOCA Proposal.30 82 The court is not in a position to comment on the assertions made by the plaintiff in this regard, but it should be observed that the administrators have properly identified, within the Voluntary Administrators' Report, a number of claims which might be advanced against the related parties. 83 The plaintiff accepts that the legislative framework does not contemplate contemporaneous administration and the appointment of a provisional liquidator: s 440A(3) of the CA. However, it submits that s 440A(3) does implicitly contemplate the appointment of a provisional liquidator if the court is satisfied that it is not in the interests of the company's creditors for the company to continue under administration. 84 According to the plaintiff, the proper question is whether the interests of the company's creditors will be better served, in the relevant circumstances, by a provisional liquidator being appointed than by the continuance of the voluntary administration. 85 The plaintiff says the appointment of a provisional liquidator would be apt in the current circumstances. The plaintiff places reliance on the following observations of Black J in In the Matter of Pages Equipment Pty Ltd,31 in deciding to appoint provisional liquidators to companies already in administration: … it seems to me that there are strong grounds for an independent investigation of the relevant transactions, which a provisional liquidator could undertake in the period pending a winding up application. The period of time available to a provisional liquidator, and the nature of his or her role, is such that he or she would have a greater focus on investigation, than a voluntary administrator would likely have within the relatively confined timetable available for a voluntary administration 30 PS [45]. 31 In the Matter of Pages Equipment Pty Ltd [2020] NSWSC 959 [18]. -- 25 of 41 -- [2026] WASC 270 LUNDBERG J Page 26 86 In the alternative, it is submitted that a special purpose administrator would be appropriate, under s 447A of the CA.32 The plaintiffs submit that Mr Zhang is the 'alter ego, controller and ultimate owner of all of assets and entities within the Corporate Group Structure, from which the Administrators are being paid'.33 Further, it is submitted that he is:34 …simultaneously funding the Administrators and Mr Zhang is the obvious target of a significant and strong insolvent trading claim, where it appears that the Administrators have failed to express the strength and magnitude of that claim and they have simply taken Mr Zhang's word for facts where the objective indicia of those facts contradict that word, especially as to Mr Zhang's financial capacity. 87 Certainly, it may be accepted that the appointment of the administrators by the sole director of the defendant in this matter came at a late stage, after the winding up application had been filed by the plaintiff (and well after the statutory demand had been served by the plaintiff). The lateness of such an appointment is a relevant factor to consider in weighing whether to adjourn winding up proceedings and whether to allow the administration to continue.35 The position of the present administrators 88 At the hearing on 30 June 2026, the administrators adopted something of a conciliatory attitude, although the plaintiff suggests that this outbreak of goodwill is rather overdue and comes quite late in the day. 89 The administrators proposed that the second creditors' meeting be adjourned such that no resolutions under s 439C of the CA to determine the future of the defendant be put to creditors, until on or around 21 July 2026. In the intervening period, the administrators indicated they intended to re-visit the matters raised by the plaintiff and continue to fulfil their duties. In conjunction with this, the administrators proposed that the plaintiff's winding up application against the defendant be adjourned. 90 In essence, the administrators emphasised the swift process which had been undertaken on their part over recent weeks, since their 32 Relying on Hughes v Westgem Investments Pty Ltd (recs and mgrs apptd) (No 3) [2012] WASC 360 [4] to [6] and Sev.en Gamma a.s. v IG Power (Callide) Pty Ltd [2024] FCA 30; [2024] 172 ACSR 136. 33 PS [62]. 34 PS [63]. 35 Re Offshore & Ocean Engineering Pty Ltd [2012] NSWSC 1296; In the matter of Vietnam Industrial Investments Pty Ltd [2022] NSWSC 1411 [15] (Black J). -- 26 of 41 -- [2026] WASC 270 LUNDBERG J Page 27 appointment, consistent with their statutory duties and the need for expedition. To the extent further work is needed by them to explore the claims which the plaintiff wishes to be further investigated, they are prepared to do that, given further time. 91 As to the viability of an insolvent trading claim, the administrators observed that, even if the quantum of the claim were increased, pursuit of the claim would give rise to several difficulties.36 92 These difficulties include the costs required to pursue an insolvent trading claim, that the defendant received support from its related entities, which can be taken into account in assessing the defendant's insolvency, the potential defences available under s 588H of the CA, and the uncertainty of recoverability against the director. 93 The administrators submit that 'there is a significant difference between a claim that, if pursued at great expense, may result in recovery, and cash' and criticise the plaintiff's statement that the 'potential return' from a claim may be great, while ignoring the risks that pursuing that claim would only cost the creditors.37 94 Accordingly, the administrators submit that: 38 …even if the estimated quantum of the insolvent trading claim is increased, there would be many reasons why that amount might not be recovered. Consequently, there would nevertheless be a practical prospect that the administration would result in a better return to creditors than a winding up. Relevant principles 95 The principles set out below are, on my assessment, relatively orthodox. In summarising these principles, I have drawn on the submissions helpfully prepared by the administrators.39 96 I have earlier set out the terms of s 440A of the CA. The central question posed by the present applications, having regard to the express language of s 440A, is whether the court is satisfied that it is in the interests of the creditors of the defendant for the company to continue under administration rather than be wound up. 36 DS [29]. 37 DS [30]. 38 DS [31]. 39 DS [8] – [21]. -- 27 of 41 -- [2026] WASC 270 LUNDBERG J Page 28 97 This statutory provision, particularly s 440A(2), requires a consideration of the competing policy considerations that administration may prove more beneficial to creditors if permitted to run its course and that winding up applications be determined quickly.40 98 The court is required to consider whether there is persuasive evidence of any real practical prospect, as opposed to mere speculation, that creditors would receive a better outcome in an administration, including the prospects of salvage-ability through allowing the administration to proceed.41 The possibility that a deed of company arrangement might emerge that would give creditors a quicker and better dividend than a winding up is one factor which may support continuing the administration.42 99 As noted by counsel for the administrators in his submissions, other factors that may support an adjournment of a pending winding-up application, in the face of a continuing administration, include:43 (a) that the administration process enables the creditors to exercise commercial judgment as to where their best interest lie; (b) that contributions to a deed fund that are to be made by related parties which would not be available if the company enters liquidation; and (c) the administrator's support for an adjournment. 100 As to the appointment of a provisional liquidator, the terms of s 440A(3) are relevant, which require a focus on the interests of the company's creditors.44 101 A provisional liquidator is usually appointed to preserve the status quo pending the determination of the winding up application.45 Pursuant to s 472(2), a provisional liquidator may be appointed after the filing of a winding up application and before the making of a winding up order. 40 Re Offshore & Ocean Engineering Pty Ltd [16]. 41 Lubavitch Mazal Pty Ltd v Yeshiva Properties No 1 Pty Ltd [2003] NSWSC 535; (2003) 47 ACSR 197 [78]. 42 Lubavitch Mazal Pty Ltd v Yeshiva Properties No 1 Pty Ltd [74]. 43 Re Grandview Ausbuilder Pty Ltd (admins apptd) [2019] NSWSC 1243 [8]. 44 In a similar manner to s 440A(2) of the CA. 45 Lubavitch Mazal Pty Ltd v Yeshiva Properties No 1 Pty Ltd [105]. -- 28 of 41 -- [2026] WASC 270 LUNDBERG J Page 29 102 I accept that the appointment of a provisional liquidator is a drastic intrusion into the affairs of the company and should not be contemplated if other measures would be adequate to preserve the status quo.46 Such an order is exceptional.47 103 Counsel for the administrators submitted, and I accept, that where, for instance, administrators have been appointed, there may be insufficient need for the appointment of a provisional liquidator.48 104 Further, generally, an undertaking as to damages is required for the appointment of a provisional liquidator.49 105 As to the removal of incumbent administrators, such an order should not be made unless it is demonstrated that it would be better for the conduct of the administration.50 This requires that attention be given to the stage of the administration and the remaining functions of the administrator. 106 The onus is on the party seeking removal, which will not be easy to discharge if the administrator has become well acquainted with the business and affairs of the company.51 107 Further, as to questions of independence and conflicts of interest, the court accords to the fair-minded observer knowledge of the reality of how administrators are selected and appointed. Allegations of bias and conflict may reflect the tensions that are often present in an administration.52 108 Finally, as to the appointment of special purpose administrators, there was no dispute on this application that the court had power to make such an appointment. In general terms, and without being exhaustive, the court may appoint special purpose administrators in circumstances similar to those which courts have found sufficient to justify the appointment of special purpose liquidators.53 46 Grace v Grace [2007] NSWSC 6 [28]. 47 Australian Securities and Investments Commission v Diploma Group Ltd [2017] FCA 549 [22]. 48 Australian Securities and Investments Commission v Keystone Asset Management Ltd (recs and mgrs. apptd) (admins apptd) (No 2) [2024] FCA 1040 [17]. 49 M2 Assets Pty Ltd v GT Capital Partners [2022] WASC 331 [219]. 50 Re Recycling Pty Ltd [2015] NSWSC; (2015) 107 ACSR 406 [94]. 51 Advance Housing Pty Ltd (in liq) v Newcastle Classic Developments (1994) 14 ACSR 230, 233. 52 Hughes v Receivers and Managers of Westgem Investments Pty Ltd (No 3) [2012] WASC 360 [18]. 53 Jahani, in the matter of Northern Energy Corporation Ltd (Administrators Appointed) (No 2) [2019] FCA 382 [29]. -- 29 of 41 -- [2026] WASC 270 LUNDBERG J Page 30 109 Circumstances which may justify their appointment include the following:54 (a) where there are matters that require investigation with a view to possible recovery for the benefit of creditors; (b) where the current administrators have insufficient funds and insufficient prospects of obtaining funds to pursue an investigation; (c) where a creditor is prepared to fund an investigation and recovery action, but only on condition that another administrator is appointed; and (d) where such appointment would be beneficial in the administration (or subsequent winding up) to the creditors as a whole. 110 These matters are relevant considerations, not exclusive factors, and the weight to be attributed to them will vary as the occasion requires.55 Disposition 111 Having heard from counsel for the plaintiff and for the defendant at the hearing on 30 June 2026, I consider the interests of the creditors of the defendant company as a whole would best be served by the appointment of special purpose administrators in the manner proposed by the plaintiff. 112 The drastic step of appointing a provisional liquidator should not be entertained, in all the circumstances. To do so would end the administration: s 435C(3)(g) CA.56 It is premature to do that. I reach that conclusion particularly given the stage at which the administration has reached, the work which has been undertaken to date by the present administrators, and the prospect that further investigation of the matters identified by the plaintiff may yield additional information which should be put to the creditors to permit them to decide the future of the company. 54 Deputy Commissioner of Taxation, in the matter of ACN 154 520 199 Pty Ltd (in liq) v ACN 154 520 199 (in liq) [2017] FCA 444 [64]- [85]. 55 Sev.en Gamma a.s. v IG Power (Callide) Pty Ltd [128[. 56 Re First Debenture Ltd [2015] NSWSC 1808 [6]. -- 30 of 41 -- [2026] WASC 270 LUNDBERG J Page 31 113 The decision to appoint special purpose administrators in effect is a conclusion that it is not presently appropriate to allow the administration to continue forward in its present form. Rather, the administration should continue on the basis that the presently appointed administrators remain focused on the management of the business of the defendant company and, in doing so, work to preserve value for the creditors. 114 However, the task of undertaking the investigation and analysis of the claims against the sole director and any related companies (as well as third parties) should be reserved to other persons, who will hold appointment as special purpose administrators, who will report to the court, and be funded by the plaintiff. In this regard, the court is not making any findings adverse to the present administrators. 115 The considerations evident on the materials before the court which justify this course are as follows. 116 First, the materials presently demonstrate that there are claims against the sole director of the defendant, and potentially also against related companies of the defendant, which are worthy of serious further investigation. The present administrators have identified some of these claims in their report. The plaintiff takes a more expansive view of the breadth and quantum of the claims, as well as their recoverability, but putting to one side the differences between the parties in this respect, I consider it is appropriate for further investigative work to be undertaken in relation to the claims. 117 The claims which have been identified would focus on the potential breaches of duties of the sole director, particularly concerning the transfer of the funds loaned to the defendant by the plaintiff in 2019. There is also an insolvent trading claim in prospect, and unfair preference claims. 118 Second, as to whether the present administrators should be left with the responsibility to undertake this investigative work and report to creditors once that has been done, I recognise that those administrators have indicated to the court, through counsel, their preparedness to undertake further investigations of these matters. The court does not doubt the sincerity of that indication. 119 However, there is a compelling reason in the present circumstances why the task should be reserved to others. That reason is centred on the reality that the potential claims are focused on the -- 31 of 41 -- [2026] WASC 270 LUNDBERG J Page 32 conduct of the sole director who was responsible for the appointment of the present administrators and, more importantly, a person who is the driving force behind the DOCA Proposal which is to be considered by the creditors (although it should be recognised that related party creditors are excluded from participation in the deed fund). 120 Importantly, the present administrators have recorded their recommendation that creditors vote on that proposal. 121 These matters strongly incline me to the view that wholly independent persons should be charged with the responsibility of investigating the claims which have been outlined. The observations made by Sifris J in State of Victoria v CTM Training Solutions Pty Ltd (In Liq) & Ors57 are apposite in this regard in the context of administrators: I should also stress that it is of the first importance that liquidators are totally independent and are seen to be so. It is important that confidence in the integrity, objectivity and impartiality of an administration be maintained. 122 Third, I consider it is highly relevant that the administrators have had limited time to make any assessment of the potential claims against the sole director and others (as well as the recoverability of the claims). They were appointed on 8 June and reported to creditors less than three weeks later, on 23 June. The types of claims in question would benefit from further analysis, as would the extent of the recoverability from the potential targets of the claims. 123 Fourth, and allied to the preceding points, I regard it as significant that the sole director and the related parties have presently resisted demands from the present administrators to provide further documentation in several respects. The administrators have noted the resistance from these parties in their report. I refer to the following matters recorded in the Administrators' Report: We have requested information from the related parties to determine the financial capacity and willingness of these entities to support the Company's historical and ongoing obligations and have not received a response at this time. [at p 44]. Following our appointment, we requested the Director provide a statutory declaration outlining their respective personal asset and liability positions. To date, we have yet to be provided with same. 57 State of Victoria v CTM Training Solutions Pty Ltd (In Liq) & Ors [2017] VSC 47 [43] (Sifris J). -- 32 of 41 -- [2026] WASC 270 LUNDBERG J Page 33 However, the Director has claimed that he has no significant personal Australian-based assets. [at p 53] At this stage, the Administrators have not received any evidence or statement from the Director regarding any assets held in another jurisdiction. [at p 53] We have requested further financial information from the Deed Proponents regarding their capacity to make any top up payment that may be required to ensure that $1.2m is contributed to the deed fund as set out on the previous page. At the time of writing this report, we are yet to receive this information. [at p 56] 124 It appears the sole director and the related parties may be adopting something of a recalcitrant attitude at this stage, in the face of requests from the administrators. That attitude may change. The court's expectation is that it would change, and there would be less resistance to the steps being taken by the administrators. However, the fact of the resistance to date provides support for a decision to appoint wholly independent parties to undertake the investigative work going forward. 125 Fifth, I consider it would be in the interests of the creditors that the present administrators be permitted to focus on the process of managing the defendant's cattle business, rather than on the potential claims which have been identified against the sole director and related parties. The administrators have pointed to the difficulties in managing the business and the need to ensure animal welfare is maintained. The administrators point to operational risks with the business, including weather, feed availability and veterinary contingencies which must be managed, in order to ensure the herd's optimal realisation window is not missed or compressed. 126 The appointment of separate professionals to examine and investigate the identified claims, and manage the communications with the director and related parties and their advisers regarding the claims, will mitigate the risks identified by the administrators concerning the ongoing management of the business. 127 In forming this view, I do not minimise the animal welfare issues that have been identified. There is a factual dispute between the parties in this regard, which involves matters concerning cattle husbandry. The court is not capable of resolving this dispute on the present materials. That will need to wait for another day. At present, I consider the short-term risks identified can be managed by the present administrators on an ongoing basis. -- 33 of 41 -- [2026] WASC 270 LUNDBERG J Page 34 128 Sixth, I recognise that the costs of the administration to date are substantial, and are growing. Extending the period of administration through the appointment of special purpose administrators will mean these costs continue to grow. These accumulating costs will have a priority over the claims of the company's creditors. Against this, it is relevant that the plaintiff creditor is proposing to fund the special purpose administrators, in the amount of $200,000.58 That funding source mitigates the administrators' concerns as to the level of the accumulating costs to a significant degree, in my view. 129 Seventh, I also recognise the concerns expressed by the present administrators as to the impact of delays on the company, the interruption of the voluntary administration process, the potential loss of the DOCA Proposal, and the potential delays to the refinance of the secured creditor's debt. These are matters properly identified by the administrators as being relevant to the applications advanced by the plaintiff. These matters must be seen in context, though. An important part of the context is that the administration process, while it has proceeded quite rapidly to the point of a DOCA Proposal being advanced, was initiated by the sole director late in the day and after a considerable period of time, it would seem, during which the defendant company was operating in financially straitened circumstances. This is a relevant and weighty consideration here given the preceding efforts undertaken by the plaintiff creditor to pursue its debt against the company, which were either ignored or resisted. 130 It is open to infer that the sole director has belatedly pursued the voluntary administration in order to forestall the plaintiff's genuine attempts to pursue its debts. That does not operate, in and of itself, to somehow invalidate the administration process under pt 5.3A. But it is a relevant factor when considering the plaintiff's present application to appoint special purpose administrators. 131 In these circumstances, while the appointment of the special purpose administrators will lengthen the administration process and provide some disruption, those are difficulties the company and its creditors will need to absorb in order to permit a more fulsome examination of the important potential claims which the plaintiff has identified. The further examination of those claims may also provide a firmer foundation than presently exists to quantify the claims and assess their recoverability, which I consider is in the interests of all creditors, 58 PS [40]. -- 34 of 41 -- [2026] WASC 270 LUNDBERG J Page 35 particularly when one appreciates the precarious financial position of the business at present. 132 Eighth, returning to the DOCA Proposal and its potential fragility if the administration process runs further, I have taken into account the concern expressed by the administrators in this regard. The risk must be seen in the context that the administrators themselves have acknowledged that the DOCA Proposal is dependent upon finance approval, which is subject to an 'indicative letter of offer for the refinancing' which has not yet been issued.59 133 That is, the Administrators' Report acknowledges that the administrators have not yet received full financial information from the DOCA proponents to confirm their capacity to make any top-up payment required to ensure $1.2m is contributed to the deed fund. 134 The DOCA Proposal is thus conditional and its funding remains partly unconfirmed. These matters must be given weight, in my view, when viewing the financial outcomes identified by the administrators in the various scenarios, which have led the administrators to recommend the DOCA Proposal as a superior outcome for creditors. 135 Ninth, as matters stand, I do not assess the appointment of special purpose administrators as introducing significant risks for the present employees of the business. 136 Tenth, the position proposed by the plaintiff is that the special purpose administrators would be funded by the plaintiff and, further, the orders drafted by the plaintiff preclude the special purpose administrators from being indemnified from the defendant's property or asserting a lien over the defendant's property. That is, s 443D to s 443F of the CA will not apply to their appointment. Conclusion and orders 137 For the foregoing reasons, I consider it appropriate to make the appointment sought by the plaintiff of special purpose administrators, to the defendant company, and to allow the administration process under pt 5.3A of the CA to continue, in the interests of the creditors. The present administrators will not be removed, but will continue in office, subject to and conditioned by the regime proposed by the plaintiff. 59 Cook Affidavit, p 220. -- 35 of 41 -- [2026] WASC 270 LUNDBERG J Page 36 138 I have set a further date for a hearing, being 3 August 2026, by which time the special purpose administrators will, on the current timetable, have prepared their report. 139 A question was raised at the hearing as to whether an undertaking as to damages was required to be proffered by the plaintiff as a condition of the appointment. While that would be required as a pre- condition to the appointment of a provisional liquidator, it was not suggested that such an undertaking was essential in the context of special purpose administrators. I would not have required it, in any event, in the circumstances of the present case. 140 The orders set out in Attachment A to these reasons were made by the court on 30 June 2026, and the orders set out in Attachment B to these reasons were made on 2 July 2026. -- 36 of 41 -- [2026] WASC 270 LUNDBERG J Page 37 ATTACHMENT A Orders made on 30 June 2026 -- 37 of 41 -- [2026] WASC 270 LUNDBERG J Page 38 ATTACHMENT B Orders made on 2 July 2026 -- 38 of 41 -- [2026] WASC 270 LUNDBERG J Page 39 -- 39 of 41 -- [2026] WASC 270 LUNDBERG J Page 40 -- 40 of 41 -- [2026] WASC 270 LUNDBERG J Page 41 I certify that the preceding paragraph(s) comprise the reasons for decision of the Supreme Court of Western Australia. LM Associate to the Honourable Justice Lundberg 2 JULY 2026 -- 41 of 41 --