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Snapshot

  • In a recent decision, the Full Court of the Federal Court of Australia has unanimously endorsed the key principles of statutory interpretation.
  • The Court re-affirmed the principles of statutory interpretation including analysing the statutory text, the statutory purpose and the historical context of the legislative provisions in issue.
  • The MetLife decision also illustrates the role that extrinsic materials can play when interpreting statutes.

In MetLife Insurance Limited v Australian Financial Complaints Authority Limited and Brian Ronald Edgecombe [2022] FCAFC 173 (27 October 2022) (‘Metlife’), the Full Court of the Federal Court of Australia (Middleton, Jackson and Halley JJ) unanimously re-affirmed the key principles of statutory interpretation.

MetLife had issued an insurance policy to the trustee of a superannuation fund. Under the policy, MetLife would pay the trustee a benefit if a fund member satisfied the definition of total and permanent disability.

Mr Edgecombe was a fund member. He made a complaint to AFCA against MetLife regarding the non-payment of such a benefit under the policy (‘2018 Complaint’).

The first provision of Subdiv A of Div 3 in Pt 7.10A of the Corporations Act 2001 (Cth), s 1053 provides:

‘Subdivision A—When complaints relating to superannuation can be made under the AFCA scheme

1053    When complaints relating to superannuation can be made under the AFCA scheme

(1)  A person may … make a complaint relating to superannuation under the AFCA scheme only if the complaint is a complaint: [ten categories are then set out in paragraphs (a) to (j)]

…

(3) A complaint made in accordance with subsection (1) of this section is a superannuation complaint [emphasis in original].’

The underlying issue was whether AFCA had jurisdiction to determine the 2018 Complaint.

Summary of the contest

MetLife contended that AFCA did not have jurisdiction to determine the 2018 Complaint whereas AFCA contended that it did. The contest arose from the competing interpretations of s 1053.

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