Selected cases

Federal Court of Australia · [2026] FCA 49

Angelis v CP PPSA information request

A Federal Court PPSR case about a PPSA information request, secured debt figures and why evidence matters when challenging a...

Federal Court of Australia2 Feb 2026

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Quick read

  • A PPSR dispute can become much harder to manage if the secured amount, loan records and security documents are not clear from the start.
  • A Federal Court PPSR case about a PPSA information request, secured debt figures and why evidence matters when challenging a security-interest response.

Use this to check

  • PPSA information requests need specific responses about the security agreement and secured obligation.
  • A late response can still affect whether urgent Court relief is useful.
  • Different debt figures are not enough by themselves if the evidence does not prove the response is wrong.

Decision snapshot

  1. What happened

    • George Angelis asked the Federal Court for an interlocutory order under s 280 of the Personal Property Securities Act 2009.
    • He wanted CP Pty Ltd to provide what he said was a complete and correct response to a PPSA information request sent on 21 May 2024.
    • The request concerned CP's security interest and sought a copy of the relevant security agreement and a statement of the amount or obligation secured.
    • CP had not responded within the statutory time, but its solicitors later sent a letter on 30 January 2026.
  2. What the court had to decide

    • The Federal Court had to decide whether CP Pty Ltd had provided an incomplete or incorrect response to a PPSA s 275 request, so that an order should be made under s 280 requiring a complete and correct response.
    • The key issue was whether the Court had enough evidence on the interlocutory application to find that CP's 30 January 2026 response was wrong or incomplete.
  3. What the court decided

    • The Court dismissed Mr Angelis's interlocutory application and ordered him to pay CP's costs of the application.
    • The Court was not satisfied, on the evidence before it, that CP's 30 January 2026 response was incomplete or incorrect.

Practical impact

Practical read

  • A PPSR dispute can become much harder to manage if the secured amount, loan records and security documents are not clear from the start.
  • Businesses using emergency finance, asset security or related-party lending should keep the security agreement, secured amount and repayment position easy to prove.

Useful next steps

  • PPSA information requests need specific responses about the security agreement and secured obligation.
  • A late response can still affect whether urgent Court relief is useful.
  • Different debt figures are not enough by themselves if the evidence does not prove the response is wrong.
  • PPSR disputes should be prepared around documents, dates, interest calculations and the exact security interest.
  • If the same issue is already headed to trial, an interlocutory application may not be the best place to resolve contested facts.

Practical read

This is a small but useful PPSR case because it shows how quickly a secured finance dispute can become about records, timing and proof. The request was not a general complaint about fairness. It was a specific PPSA request for security-interest information: the security agreement, the amount secured and the terms of payment or performance.

CP was late to respond, but by the time the application was heard it had provided a response with principal and interest figures. Mr Angelis said the figures did not line up with earlier versions of the amount allegedly owing. The problem was evidence. The Court was told the material needed to decide that factual dispute sat in a six-volume court book for the trial. On the interlocutory application, the Court was not satisfied there was enough evidence to find CP's response incomplete or incorrect.

For businesses, the lesson is practical. If you register or rely on a PPSR security interest, assume someone may later ask for the documents and the secured amount. If you challenge a PPSR registration, keep the dispute focused on the actual agreement, the obligation secured, the dates, the interest calculation and the evidence that proves any inconsistency. A rushed application may fail if the Court cannot safely decide the factual issue on the material in front of it.

Checks to run

Key points

  • Keep every PPSR security agreement, variation and repayment record in one place.
  • Record the secured amount and interest calculation as at the date of any formal request.
  • Respond to PPSA information requests within the statutory timeframe.
  • If the secured amount changes, keep a clear explanation of why each figure changed.
  • Before filing urgent PPSR applications, check whether the evidence can prove the exact inconsistency alleged.

Key takeaways

  • PPSA information requests need specific responses about the security agreement and secured obligation.
  • A late response can still affect whether urgent Court relief is useful.
  • Different debt figures are not enough by themselves if the evidence does not prove the response is wrong.
  • PPSR disputes should be prepared around documents, dates, interest calculations and the exact security interest.
  • If the same issue is already headed to trial, an interlocutory application may not be the best place to resolve contested facts.

Related topics

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Update history

Case8 June 2026

Current PPSR, employment and patent cases added

Six current Federal Court explainers were added for PPSR finance records, indemnity deeds, Fair Work pleadings and costs, retail underpayment timing and patent amendments.