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Federal Court of Australia · [2026] FCA 532

Sozou, in the matter of Comm TC

A Federal Court liquidation case extending time for liquidators of labour hire companies to investigate and pursue potential voidable...

Federal Court of Australia1 May 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.

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Quick read

  • Poor company records and unexplained related-party payments do not disappear when a company goes into liquidation.
  • A Federal Court liquidation case extending time for liquidators of labour hire companies to investigate and pursue potential voidable transaction claims.

Use this to check

  • Liquidators can seek more time to investigate and bring voidable transaction claims.
  • Inadequate books and records can be a strong explanation for investigation delay.
  • Labour hire and intercompany arrangements need pricing, invoices and payment records that make commercial sense.

Decision snapshot

  1. 1

    What happened

    • Comm TC and Zenith Workforce NSW were companies in liquidation within a broader group of labour hire companies in the construction industry.
    • Katherine Sozou, Anthony Connelly and William Harris were appointed as replacement liquidators in May 2025 after an earlier liquidator had faced problems progressing the administrations.
    • The evidence showed inadequate books and records, limited cooperation, funding constraints and a need for further investigations.
    • The liquidators identified potential voidable transaction claims, including a possible uncommercial labour hire arrangement involving Comm TC and Commercial TC with an estimated potential shortfall of up to $4 million, as well as other payments said to be outside the ordinary course of business.
  2. 2

    What the court had to decide

    • The Court had to decide whether it was fair and just to extend the time for the liquidators to bring applications under s 588FF(1) for identified and unidentified voidable transaction claims, and whether confidentiality orders should protect sensitive evidence about investigations and potential recoveries.
    • The Court balanced commercial certainty for potential defendants against the interests of creditors in preserving recovery claims.
  3. 3

    What the court decided

    • The Federal Court extended the time for identified potential claims to 1 March 2027 and for other potential claims to 29 April 2028 for both Comm TC and Zenith.
    • It also made confidentiality orders over the confidential affidavit and exhibit, and ordered that the proceeding costs be costs in the winding up of the companies.

Practical impact

Practical read

  • Poor company records and unexplained related-party payments do not disappear when a company goes into liquidation.
  • They can give liquidators more reason to seek extra time, run examinations and preserve voidable transaction claims.
  • For businesses, the safest pattern is to keep labour hire, intercompany, supplier and director-linked payments commercially explainable at the time they are made.

Useful next steps

  • Liquidators can seek more time to investigate and bring voidable transaction claims.
  • Inadequate books and records can be a strong explanation for investigation delay.
  • Labour hire and intercompany arrangements need pricing, invoices and payment records that make commercial sense.
  • Transactions outside the ordinary course of business can attract later scrutiny.
  • Potential defendants should expect notice and a chance to object where extension orders may affect them.

Practical read

This case is about the time liquidators need when a company group's records are poor and the money trail is complicated. Comm TC and Zenith were part of a labour hire group in the construction industry. The new liquidators had to pick up an administration where the earlier liquidator had faced inadequate records, limited cooperation and funding constraints.

The liquidators asked the Court to extend the time for bringing voidable transaction claims. That matters because the Corporations Act places time limits on applications to recover certain transactions made before liquidation. If time expires before investigations are complete, potentially valuable recovery claims for creditors can be lost.

The Court accepted that the liquidators had done substantial work in a relatively short period. They had gathered and reviewed records, conducted forensic analysis, identified possible claims and recovery avenues, engaged legal advisers and prepared for public examinations. The possible claims were not just vague suspicion. The public reasons referred to a proposed uncommercial transaction claim arising from a labour hire arrangement and to specific payments said to sit outside the ordinary course of business.

For business owners, the message is direct. When a company fails, poor records can extend the pain. Related-party payments, labour hire arrangements, intercompany dealings, director-linked payments and unexplained withdrawals may all be tested later. If the commercial reason for a transaction is not clear in the records, liquidators may spend years investigating it and potential defendants may stay exposed for longer.

Checks to run

Key points

  • Keep labour hire contracts, timesheets, invoices and margin calculations in one reliable record set.
  • Document the commercial reason for payments to directors, relatives, group entities and unusual suppliers.
  • Avoid treating intercompany balances as informal if companies trade as a group.
  • Cooperate with external administrators and provide books and records promptly.
  • Preserve bank statements, payroll files and customer contracts if insolvency is possible.
  • Review unusual transactions early when a company is under financial stress.

Key takeaways

  • Liquidators can seek more time to investigate and bring voidable transaction claims.
  • Inadequate books and records can be a strong explanation for investigation delay.
  • Labour hire and intercompany arrangements need pricing, invoices and payment records that make commercial sense.
  • Transactions outside the ordinary course of business can attract later scrutiny.
  • Potential defendants should expect notice and a chance to object where extension orders may affect them.
  • Confidentiality orders can protect sensitive investigation material where disclosure would prejudice recoveries.

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