Monday, 16 December 2013

Statutory Licences Required to Operate Business

Many businesses require statutory licences in order to operate within the law. These licences are effectively legal permits to enable an operator to conduct the business. The reasons for creation of such licences under the particular statute may be to regulate the operations of a particular business either by restricting the types of persons able to conduct that business to those properly qualified, or to restrict the number of persons in a particular area who may conduct such business. Such a licence may be described in a variety of ways.
For example, in Queensland Retail Milk Vendors' Association v Deacon, a licence to operate a milk-run was referred to as a lease. It was not a lease in the true sense but merely a right to operate that run for a limited period in return for payments. The right to a licence is certainly analogous to a property right. However, much might depend upon the nature of the right and how it is created.

Similarly, a licence to operate a business would normally be treated as part and parcel of the property being sold particularly where the question arose as to whether it was part of the conveyance of property of the business which might be dutiable. For example, in Commissioner of Stamp Duties (NSW) v Yeend, the court examined the right to sell refreshments in two reserved enclosures at race meetings at Warwick Farm racecourse. This right was held by the High Court to be no more than a contractual right and not a property right. It was analogous to a personal right to place posters on a wall or to take photographs. The effect of that decision would be to discriminate between the contract which brings into existence a merely personal right, not itself being a right of property, and merely a right personal to that particular licensee. This has been held in respect of a statutory licence where the object of the statute was to licence a particular person to conduct a nominated business and not to create a right of property.

Whilst a statutory licence could never attract customers, it operates to the holder's advantage by ensuring that by a lack of choice, the number of people issued with these licences will be restricted. Because it does not influence or secure custom in any other way it is probably wrong to refer to such a licence as property although its possession certainly enhances the goodwill of a business.

A franchise right, although contractually conferred, could also operate as a property right depending upon the nature of the franchise. Whilst there is a degree of judicial difference of opinion as to the true nature of these rights, they are plainly analogous to property although technically not goodwill, but are nonetheless valuable rights. There are many cases dealing with the question of whether or not a liquor licence, which is a grant of a statutory monopoly to sell liquor, is part of the goodwill of a business. It has been suggested that goodwill attaches to a statutory monopoly right and that whilst such a right can be dealt with separately from goodwill, it is not usually severable from the goodwill for practical purposes. This is so in the sense that the goodwill attaches to a species of property and the goodwill can only be dealt with attached to that statutory right. However, that is not to say that the separate statutory right itself cannot be the subject of a separate bargain and sale apart from the goodwill.

It is interesting to note that a statutory licence granted by a government agency authorising the operation of a business may give other rights to that licence holder. For example, in Ball v Consolidated Rutile Ltd, commercial fisherman (the plaintiffs) were granted licences under fishing legislation of Queensland which authorised them to take prawns for commercial purposes by the use of nets from licensed fishing vessels in specified waters. The activities could not be conducted without such licences so the plaintiffs' authority to conduct their business derived entirely from legislation.

The defendants conducted sand mining operations on an island adjoining the fishing grounds. As a result of their operations part of a large sand dune slipped into the water taking with it a great deal of root masses and other vegetation which was carried into the fishing grounds. The plaintiffs complained that the damage had caused destruction to their fishing equipment and it was no longer economical to fish in the waters for which they were licensed to fish. The plaintiff fishermen claimed damages against the corporation for public nuisance by failing to take reasonable precautions to prevent slippage and causing economic loss to the plaintiffs who had to cease fishing in the area in which they were licensed.

In the result Ambrose J, who found that the defendants were not liable in public nuisance, did recognise that there may have been a public right conferred by the statutory provision which licensed the fishermen? Again, the licence was not a recognisable species of property but arguably gave certain common law rights to the holders.


Thus, it may be seen, that a holder of a statutory licence may logically form part of a specific class of persons who may be in a position to take action to restrain others from interfering with the rights granted by such statutory licences. In different circumstances from those in which the fishermen had found themselves, such persons may sustain claims for loss, including economic loss, if that loss is suffered through infringement of that statutory right. The right, as was found in the above case, need not be necessarily described as a property right.

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