EOFY Sale · Save up to $750 off your legals · Ends 30 June

Claim offer
Selected cases

Federal Court of Australia · [2026] FCA 286

Ramoo v Grow Trade Finance

A Federal Court trade finance case about a director's personal guarantee, a facility increase, PPSR enforcement and receivers.

Federal Court of Australia18 Mar 2026

Plain-English explainers, not legal advice. Check the linked official source before you rely on a specific section, and get advice for your situation.

Get legal help

Start here

Quick read

  • Director guarantees and trade finance variations need careful signing mechanics.
  • A Federal Court trade finance case about a director's personal guarantee, a facility increase, PPSR enforcement and receivers.

Use this to check

  • A director can sign one transaction in both company and personal capacities.
  • Facility increases should clearly confirm whether the guarantor consents personally.
  • PPSR and charge wording can matter when a lender seeks rights over personal property.

Decision snapshot

  1. 1

    What happened

    • Medoc International Pty Ltd operated a timber wholesale business across four Australian states.
    • Grow Trade Finance provided Medoc with a trade finance facility in February 2019, initially limited to $100,000.
    • Ms Rani Ramoo, Medoc's sole director, signed the agreement both personally and as director.
    • The agreement contained guarantee, indemnity and charge terms over her personal property.
  2. 2

    What the court had to decide

    • The Federal Court had to decide whether Ms Ramoo's personal guarantee remained on foot after the facility variation, whether the receivers were validly appointed, whether Grow Trade could rely on section 123 of the Personal Property Securities Act to seize personal property, and whether any demand or court order was required before enforcement.
  3. 3

    What the court decided

    • The Court dismissed Ms Ramoo's originating application and allowed Grow Trade's cross-claim to the extent of the declarations made.
    • It declared that the personal guarantee had not been discharged and that section 123 of the Personal Property Securities Act operated so Grow Trade, directly or through receivers, could seize Ms Ramoo's personal property in the exercise of rights conferred by the agreement or by another method permitted by law, with liberty to apply about method of seizure.

Practical impact

Practical read

  • Director guarantees and trade finance variations need careful signing mechanics.
  • If a director signs both for the company and personally, later increases to a credit limit can expose personal assets unless the guarantee and variation documents are controlled.

Useful next steps

  • A director can sign one transaction in both company and personal capacities.
  • Facility increases should clearly confirm whether the guarantor consents personally.
  • PPSR and charge wording can matter when a lender seeks rights over personal property.
  • Guarantee disputes often turn on documents signed years before default.
  • Use separate signing blocks for company execution and personal guarantees.

Practical read

This is a very practical finance case. A company needed trade finance. The sole director signed the facility documents in two capacities: for the company and personally. The credit limit later increased. When the company defaulted, the dispute became personal: was the director still bound, had the guarantee been discharged, and could the lender or receivers seize her personal property?

The case shows how much turns on signing blocks, variation letters and security wording. A director may think they are signing to keep the business funded, while the lender sees a continuing personal guarantee and charge. If a credit limit changes later, the documents need to make clear whether the guarantor is consenting personally, not only as the company's officer.

For small businesses, the lesson is direct. Do not sign trade finance, supplier credit or invoice funding documents in a hurry without separating company obligations from personal obligations. If you are a director, check whether a variation increases your personal exposure. If you are the lender or supplier, make the guarantor consent obvious and keep PPSR and receiver rights aligned with the documents.

Checks to run

Key points

  • Use separate signing blocks for company execution and personal guarantees.
  • Require guarantor acknowledgement for every material facility increase or variation.
  • Review PPSR registrations and security wording before relying on personal property rights.
  • Keep default notices, demands and receiver appointments in a single enforcement file.
  • Get advice before signing supplier credit or trade finance terms that include personal charges.

Key takeaways

  • A director can sign one transaction in both company and personal capacities.
  • Facility increases should clearly confirm whether the guarantor consents personally.
  • PPSR and charge wording can matter when a lender seeks rights over personal property.
  • Guarantee disputes often turn on documents signed years before default.

Related topics

How Sprintlaw can help