Legislative Reform Archives

Can you make an adverse possession claim over a neighbouring strata lot in WA?

Question:

Can you make an adverse possession claim over a neighbouring strata lot in WA?

Answer: yes

In Anderson v Stone [2026] WASC 323, the Supreme Court of Western Australia declared that the owner of a lot in a WA strata scheme had acquired absolute title by adverse possession to part of a neighbouring strata lot and ordered that the land be amalgamated into her lot.

The area in question formed part of a passage between the two dwellings which provided the only access to the rear of the owner’s residence. She had used it exclusively since she became the registered proprietor, storing items there and accessing her lot through it.

A right of adverse possession arises because a landowner’s right to bring an action to recover the land is barred by the expiry of the limitation period of 12 years, at which point their title is extinguished. The claimant must establish both factual possession and an intention to possess and that possession must have been continuous, open, peaceful and without the consent of the owner.

The owner had already obtained the Registrar of Titles’ approval of an adverse possession claim over a larger area and the strata plan had been amended accordingly. The area the subject of this case had been removed from that application following requisitions by Landgate, leaving declaratory relief in the Supreme Court as a remaining option.

The application was unopposed and the decision turned on its own facts, with the owner being successful in their claim for title by adverse possession. It is nevertheless a reminder that boundaries within a strata scheme are not immune from adverse possession and that it can be significantly detrimental for a party who waits too long to take action against an encroacher. The concept poses an interesting query as to how the doctrine of adverse possession operates in respect of the common property in a strata scheme.

If you require advice regarding an adverse possession claim or property disputes, please do not hesitate to contact the team at our Perth office.

This article was first published on 17 August, 2026 and was written by Jonathan O’Connor, Senior Associate in our Perth office.
© Bugden Allen Group Legal Pty Ltd. This is general information only and not legal advice. You should not rely on this information without seeking legal advice tailored to your specific circumstances.

Body Corporate Body Corporate disputes common property common property improvements disposal of common property Queensland strata strata approvals Sun Lagoon

When is ‘just laying some pavers’ actually a disposal of common property?

A Queensland body corporate Adjudicator draws the line between an “improvement” and a “disposal” of common property: Sun Lagoon [2026] QBCCMCmr 253

Every body corporate has, at some point, faced a version of this problem: one owner wants to do something to the common property that benefits their own lot. A deck. A garden bed. In this case, pavers. The other owners are quick to ask the obvious question — is body corporate approval needed, and if so, at what level? Approval can vary from a simple committee resolution on the one hand, all the way to a resolution without dissent at a general meeting. This recent decision from the Adjudicator Ananda helps lot owners and committee members find the line between improving and disposing of common property.

What was the dispute about?

Sun Lagoon is a 30-lot scheme at Noosa Heads. The owner of Lot 9 wanted to remove a roughly 3 by 3 square metre section of grass and garden on common property next to the back (sliding) door of their lot, and lay pavers in its place, matching paving that the owners of the neighbouring Lots 8 and 10 had been allowed to install back in 2011. The owner of Lot 9 (a related entity to the management rights operator) put forth a motion at the body corporate’s Annual General Meeting on 18 September 2025 (Motion 18A) asking the body corporate to approve the works as an “improvement to common property”, requiring only an ordinary resolution; that is, the motion passes with a simple majority.

The body corporate’s committee did not agree, and put forward a competing motion (Motion 18B) asking the lot owners to reject Lot 9’s proposal. The committee’s concerns were that the pavers would affect the visual amenity of the complex, would occupy a meaningful area of common property, and, in substance, would end up being used exclusively by Lot 9, even though no formal exclusive use right was being sought.

Another lot owner, Grant Hailes (the owner of Lot 29 and Chairperson), went further. He argued that removing grass, topsoil and a garden bed and replacing them with pavers was not merely an “improvement” at all, it was a disposal of common property; that being a de facto grant of exclusive use, or the grant of a licence for exclusive and indefinite use of the affected patch of turf and garden. Under the legislation, either of those things would require the highest level of owner approval available: a resolution without dissent, meaning that the approval motion would fail if even only one lot owner voted against it.

At the AGM, Motion 18A received 17 votes in favour and 12 against, which would easily carry as an ordinary resolution. The Chairperson however, ruled Motion 18A out of order, taking the view that the motion should have been put forward as a resolution without dissent. That ruling is what ended up before the Adjudicator, by virtue of Mr Hailes’ application to have Motion 18A declared invalid outright.

Why does the level of approval matter?

Queensland’s body corporate legislation scales the level of owner approval according to how seriously a proposal, and resultant decision on that proposal, affects everyone’s shared interest in the common property. Routine improvements that benefit one lot but leave everyone else’s rights untouched can generally proceed as either a committee resolution (depending on the value of the improvement) or as an ordinary resolution.

Anything that amounts to selling, disposing of, or granting a long-term lease or licence over common property sits in a different category, because it affects what every owner co-owns. Selling or otherwise disposing of common property, or granting a long-term lease or licence over common property, requires a resolution without dissent; all votes cast must be in favour, and just one (or more) votes against will cause the motion to fail.

So, the entire dispute turned on a single question of substance rather than form: irrespective of how the motion was worded, did laying pavers over that area of grass and garden amount to a disposal of common property, whether by a de facto grant of exclusive use, or the grant of an exclusive and indefinite licence? If yes, the ordinary resolution the owners of Lot 9 had put forward, and had actually won, was not good enough.

The competing arguments

Mr Hailes, the Chairperson who had ruled Motion 18A out of order, pointed to a line of earlier decisions to support his case. In Katsikalis v Body Corporate for “The Centre” [2009] QCA 77, the Queensland Court of Appeal found that the extension of an advertising hoarding into (previously unoccupied) common property air space amounted to a disposition of that space, because it excluded all other lot owners from using it, apparently for good. In Dansur v Body Corporate for Cairns Aquarius CTS 1439 & Anor [2022] QCATA 15, removing a section of common property masonry to enlarge a window was found to be a disposal. In Ainsworth & Ors v Albrecht & Anor [2016] HCA 40, the High Court dealt with a lot owner absorbing a small pocket of common property airspace into their own balconies (turning two small balconies into one large balcony). Again, this was treated as something that required a resolution without dissent. On Mr Hailes’ argument, digging up the grass, topsoil and garden bed, disposing of those things, and then replacing them with pavers, for the benefit of Lot 9, was no different.

The owners of Lot 9 (represented by Bugden Allen) argued the opposite. Nothing about the proposal excluded any owner, occupier or visitor. There would be no fence, no barrier, and no legal right for Lot 9 to stop another owner, occupier or visitor from walking across the paved area, sitting on it, or otherwise using it, just as they could when it was grass. In ancient common law parlance, none of their fellow lot owners were being ‘ousted’ from the affected area of common property. Further, and in any event, the works were, they said, materially the same as what the committee had already allowed the neighbouring Lots 8 and 10 to do, back in 2011. At an installed value under $3,000, the works arguably even qualified as a “minor improvement” under the regulation; a category that, if it applied, meant that only committee approval was required.

What the Adjudicator decided

Adjudicator Ananda dismissed Mr Hailes’ application, and found that Motion 18A only ever needed the ordinary resolution it was put forward as. Three points of reasoning from Adjudicator Ananda stand out.

A “disposal” is narrower than simply changing or removing part of common property. The Adjudicator held that “disposal” in the legislation carries its everyday meaning of parting with property with some finality — closer to a sale, gift or transfer — rather than any physical alteration to common property. If digging up grass and topsoil counted as a disposal every time, a body corporate would technically need unanimous approval to mow the lawn, which cannot have been the legislature’s intention.
There was no exclusion of other owners, in law or in fact. The critical difference from Katsikalis and Ainsworth was that those cases involved a physical or legal barrier; a rooftop hoarding and an enclosed balcony, that genuinely shut other owners out. Here, nothing stopped anyone else from walking onto, or using, the paved area once it was laid. Without that exclusion, there was no “disposal” and no licence for exclusive and indefinite use.
There was no demonstrable loss to the other owners for Lot 9’s exclusive benefit. Citing Dansur, where enlarging a window changed the building’s façade to the exclusive benefit of one lot, the Adjudicator found no equivalent loss here. The pavers did not obstruct anyone’s view or access, and the area remained open to all.

On the basis of the Adjudicator’s analysis above, laying the pavers was simply an “improvement to common property for the benefit of the owner’s lot” under section 177 of the Accommodation Module. That is, the type of change that should be approved by committee resolution where it can be, and ordinary resolution if it must. Motion 18A had already cleared the higher of those two bars, with 17 votes in favour to 12 against, and the Chairperson (Mr Hailes) should not have ruled it out of order.

Why this decision matters

Ever since Dansur (actually spelled Danseur – the writer acted for that successful company in those proceedings) ‘nay sayers’ and NIMBY’s have used the Danseur decision to argue that almost any improvement to common property needs a resolution without dissent to authorise. In Sun Lagoon the learned Adjudicator went to some pains to identify, outline and analyse relevant common law, property law and body corporate legislation to reconcile, and ultimately make sense of, what appear to be competing authorities. For Adjudicator Ananda (and in our view, correctly) the decision in Danseur is authority for the proposition that:

‘…a disposal or disposition of common property was found to have occurred because (in a nutshell) there was a demonstrable loss to the members of the body corporate save the benefiting member (which it said must be greater than the loss of a negligible tangible thing such as bricks and mortar) in respect of the interest in common property, which was to the exclusive benefit of one member.’ at [100]

That is the take home message from Sun Lagoon and it is a message that will probably be repeated by Adjudicators for many years to come – since Danseur was handed down in 2022, it has been cited at least 21 times in Adjudications, often by applicants seeking a ‘silver bullet’ to stop another lot owner’s improvement to common property.

Bodies Corporate and committees can now easily explain, and apply, Danseur, which in turn should lead to better decisions on lot owner improvements, and less unnecessary disputation.

This article was first published on 13 August 2026. It was written by Michael Kleinschmidt, Legal Practitioner Director & Jade Marley, Solicitor all from our Sunshine Coast office.

ⓗ Human drafted with AI assistance

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Serving notices on owners and occupiers under the Strata Titles Act 1985 (WA) – practical tips for strata managers

Proper service is something which can be overlooked at the time a notice under the Strata Titles Act 1985 (WA) is issued. It tends to become the issue months later, when an owner disputes a levy, resists a by-law enforcement application, or challenges a resolution passed at a general meeting, and the first question asked is whether the notice was validly served.

Section 216 of the Strata Titles Act 1985 (WA) sets out the ways in which a document required or authorised by the Strata Titles Act 1985 (WA) or the scheme by-laws may be served.

The documents commonly served by strata companies and strata managers include:

notices of general meetings and of proposed resolutions;
notices of a contravention of the scheme by-laws under section 47; and
notices required or authorised under the scheme by-laws.

The importance of compliance with service requirements was illustrated in Konig and The Owners of Tranby on Swan Strata Plan 2232 [2021] WASAT 156. In that case, a strata company sought to authorise works to replace balustrades forming part of the common property by an ordinary resolution passed outside a general meeting. SAT found that owners had been given less than the 14 days’ notice of the proposed resolution required by section 123 and that, the notice period being definitional, there was no ordinary resolution. That case concerned the period of notice rather than the method of service, but the principle is the same. Where the Act prescribes how notice is to be given, non-compliance can have significant consequences.

Some core practical tips for strata managers to be aware of are as follows:

Identify who is being served. Section 216 deals separately with the strata company, owners, occupiers and other persons such as mortgagees. A method effective for an owner is not necessarily effective for an occupier.
Do not assume that email constitutes service.
Identify the correct address and appropriate method for service. Work from the strata roll where applicable. For example, an owner may be served at the address for service appearing on the roll maintained under section 105. If there is no address for service, the document may be posted to the owner at the address of the lot. Occupiers may be served by post to the lot address.
Save a copy of the roll as at the date of service where the roll is the source of the address for service. Many strata management platforms overwrite owner details when the roll is updated and do not retain a historical record. If service is challenged a year later, the strata company needs to be able to prove the address for service recorded on the roll on the day the notice was sent. Service is considerably easier to establish at the time a notice is issued than after a dispute has arisen.
Ensure any required notice periods are complied with, allowing for delivery time.

If you require advice or assistance in relation to the service of notices or any other strata company processes, do not hesitate to contact the team at our Perth office.

This article was first published on 7 August, 2026 and was written by Jonathan O’Connor, Senior Associate in our Perth office.

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Overdrawn Accounts and Inter Fund Transfers: What Every Queensland Body Corporate Manager Needs to Know post Artique

In summary: Under the Body Corporate and Community Management Act 1997 (Qld), a body corporate must never transfer money between its administrative fund and its sinking fund — no resolution can authorise it. A body corporate bank account that runs into negative territory is not a grey area either: overdrawing is borrowing, and it needs the same resolutions and approvals as any other loan. Both issues can come up in the day-to-day management of Queensland schemes, and both carry real consequences for bodies corporate, and their body corporate managers, who get the mechanics wrong.

Key takeaways

• Transferring money between the administrative fund and the sinking fund is expressly prohibited by section 167(7) of the Standard Module, and equivalent provisions in all other Regulation Modules — in both directions, and regardless of how many bank accounts the body corporate holds. • No body corporate resolution can override that prohibition, including a resolution without dissent. • An ’overdrawn’ body corporate account is legally a borrowing under section 171 of the Standard Module, requiring an ordinary resolution — or a resolution without dissent once the borrowing exceeds the relevant per-lot limit. • Having a term deposit at the same bank does not change this analysis. What matters is whether the transaction account itself is overdrawn, not whether the body corporate has other money sitting elsewhere, including (on the books) in the same ‘fund’. • Correcting a genuine bookkeeping error is not the same as a fund transfer. Moving money between budget lines within the same fund is not a fund transfer either — but it will usually necessitate an ordinary resolution to amend the budget.

Two scenarios body corporate managers see all the time

Every body corporate manager in Queensland has, at some point, dealt with one of two recurring cash flow problems. The first is the overdrawn account. A body corporate has put sinking fund money on term deposit — sensibly, because it is not needed yet — but cash flow forecasting has not kept pace with actual spending. A payment is presented, there isn’t enough in the transaction account to cover it, and the bank pays it anyway. The account sits in negative territory until either the term deposit is recalled to cover the shortfall, or enough levies come in to bring the balance back into credit. The second is the inter-fund transfer. Here, the bank account itself stays in credit, but the body corporate uses sinking fund money to cover an administrative fund expense (or the other way around), so that one fund’s notional balance goes into deficit while the bank account balance looks fine. Both scenarios feel like minor administrative hiccups. Neither is. Queensland’s strata legislation treats them very differently to each other, and far more strictly than most people expect.

Transferring money between funds is not allowed — full stop

Section 167 of the Standard Module requires administrative fund money and sinking fund money to be paid into the body corporate’s financial institution account(s), and section 167(7) then draws a hard line: ‘Funds must not be transferred between the administrative fund and the sinking fund.’ A few points flow from that wording that all body corporate managers should have front of mind:

It doesn’t matter whether the body corporate operates one bank account or several — the prohibition applies regardless of the banking arrangements.
It cuts both ways. Moving money from the sinking fund to the administrative fund is prohibited, and so is moving money the other way.
No resolution can fix it. A motion approving a transfer — even a resolution without dissent, the highest bar a body corporate can clear — is void, because it is directly contrary to section 167(7).

The underlying design is that administrative fund money and sinking fund money are meant to be quarantined from one another: each fund receives its own money (sections 167(2) and (3)), each fund can only be spent on the purposes specified for it (section 169), and there is no lawful overlap between the two.

What the case law says

The Commissioner for Body Corporate and Community Management’s adjudicators have applied these rules consistently:

In Brookwater Home Owners Club [2009] QBCCMCmr 376, it was held that a transfer between funds cannot be ordered at all, because section 167(7) expressly prohibits it.
In Pier One Hervey Bay [2018] QBCCMCmr 238, borrowing from one fund to use for another was found to itself be a prohibited transfer — not a technical breach, but the real thing. The remedy identified was for the body corporate to raise a special levy to cover the shortfall and use the proceeds to reimburse the fund the money was taken from.
In Royal Pines South Shields [2015] QBCCMCmr 363, it was held that simply paying an expense out of the wrong fund is itself a form of prohibited transfer — it makes no difference whether the liability is met directly from the wrong fund, or money is shuffled between funds first and the expense paid ‘properly’ afterwards.

A genuine bookkeeping correction is different

Not every adjustment between funds is a prohibited transfer. If money was allocated to the wrong fund in the first place — a genuine misallocation — then correcting that entry is not a ‘transfer’ because the money was never properly received into (or paid out of) the correct fund to begin with.

Moving money within a fund is a different question

An intra-fund transfer — for example, reallocating money from one line item in the sinking fund budget to another line item in the same fund — does not breach section 167(7), whether it happens physically between accounts or only in the body corporate’s books. It will, however, usually amount to an amendment of the body corporate’s current budget, which requires approval by ordinary resolution: see Mariners Village 3 [2006] QBCCMCmr 56.

An overdrawn account is a borrowing, not a technicality

There is no provision in the Act, or any of the Regulation Modules which says, in so many words, that ‘a body corporate must not overdraw its bank account’. That does not mean the position is unregulated. What is actually happening when an account goes into negative territory is that the financial institution has advanced money to the body corporate so it could make a payment it otherwise couldn’t afford — in other words, the body corporate has borrowed money, which is squarely regulated by section 171 of the Standard Module. That has real consequences:

Borrowing requires an ordinary resolution. A committee has no power to authorise it on its own.
Once total borrowing exceeds the relevant threshold — for a scheme under the Standard Module, currently $250 per lot — approval must step up to a resolution without dissent.
It makes no difference that the body corporate has a term deposit sitting at the same bank. The term deposit is a different account. What determines whether there has been a borrowing is whether the transaction account is overdrawn — not whether the body corporate has other money elsewhere that could theoretically cover the debt.

A financial institution may only be willing to let an account run into deficit because it knows there’s a term deposit in reserve, but that commercial reality doesn’t change the legal character of the transaction. The body corporate still owes the bank the overdrawn balance, and that debt is still a borrowing that needed approval before it was incurred. The recent decision in Artique [2026] QBCCMCmr 43 reinforces how granular that approval requirement is. That case concerned a multi-drawdown facility taken out by a body corporate under the Accommodation Module. It was held that each individual drawdown needs its own approval, pitched at whatever level the resulting total indebtedness requires (in that case, a special resolution once a drawdown pushed borrowing past the $250-per-lot mark), and that a body corporate cannot validly pre-approve an entire facility limit in one go without reference to how the money will actually be spent.

What a compliant overdraft facility actually requires… post Artique

Applying these principles to a body corporate account that is permitted to run into overdraft, the body corporate needs to have in place — and a properly advised financial institution should be asking for:

An ordinary resolution authorising the opening of the overdraft account, obtained before the account is opened.
A further ordinary resolution each time the account is actually overdrawn, because each drawdown is treated as a new borrowing — an overdraft facility is, in this respect, no different to a multi-drawdown loan.
Before any borrowing (or the running overdrawn balance) exceeds the applicable per-lot limit, the higher-threshold resolution required at that level — a resolution without dissent under the Standard Module.
A certified copy of the relevant general meeting minutes, provided before the account is opened or the funds are advanced, as the case requires.

In practice, this is a meaningful amount of process to comply with. Bodies corporate are often already reluctant to approve borrowing of any kind, and the administrative work and cost of calling and running the necessary general meetings — in time to actually meet a cash flow gap — tends to make that reluctance worse, not better. Strictly applied, that friction produces one of two outcomes: schemes with a genuine, ongoing need for an overdraft facility invest the time and expense to do the approvals properly, and everyone else improves their cash flow forecasting so they don’t need the overdraft facility in the first place.

Where the problem usually starts — and where a manager can genuinely help

Overdrawn accounts don’t appear out of nowhere. They can arise because of cash flow advice from a body corporate manager that was on the one hand ignored, or on the other hand was poor, incomplete, or simply never given. It’s incumbent on body corporate managers to give timely and accurate assistance, and for committees to listen to and act on that advice. Some body corporate managers even go the extra mile. In Sanctuary Shores Resort [2000] QBCCMCmr 560, a body corporate manager had a practice of personally lending money to a body corporate it managed whenever that body corporate’s account ran overdrawn, charging interest on the amount advanced. When the body corporate later received penalty interest from a lot owner on unpaid contributions, the manager would net its own interest owed off against that penalty interest received. The body corporate challenged the arrangement, but the adjudicator did not disturb it. More power to that body corporate manager, but the goal should be that borrowing is never needed – that is the mark of a well advised and well run body corporate.

What this means for body corporate managers, in practice

For a body corporate manager advising committees day to day, the practical takeaways are straightforward:

Treat cash flow forecasting as a routine part of the job, not an afterthought — it’s the single biggest lever for avoiding an overdrawn account in the first place.
Never record, facilitate, or wave through a transfer between the administrative and sinking funds, no matter how the committee frames it or how confident everyone is that ‘it’ll balance out later.’ Section 167(7) doesn’t bend for good intentions, and no resolution can authorise a breach.
If an expense has been paid from the wrong fund, or money has genuinely been misallocated, fix it with a proper correcting journal entry — and be able to explain, if asked, why it was a correction and not a transfer.
If a committee wants to reallocate money between budget lines within the same fund, get the ordinary resolution to amend the budget before treating the reallocation as settled.
Before any account is allowed to run into overdraft — or before recording an account as ‘overdrawn’ at all — make sure the right resolution has actually been passed, at the right threshold, and that certified minutes exist to prove it.

Frequently asked questions

Can a body corporate transfer money from the sinking fund to the administrative fund if everyone agrees?

No. Every Regulation Module prohibits transfers between the administrative fund and the sinking fund in both directions. Even a resolution without dissent cannot authorise it, because the resolution itself would be void.

Is an overdrawn body corporate account illegal in Queensland?

There’s no provision that names ‘overdrawing an account’ as a prohibited act. But an overdrawn balance is legally a borrowing, and borrowing without the required resolution — or beyond the approved limit — is not legal.

Does having a term deposit make it acceptable to run the transaction account into overdraft?

No. The term deposit is held in a separate account. What matters is whether the transaction account itself is overdrawn, regardless of what other money the body corporate holds elsewhere.

Can a committee approve borrowing on its own?

No. Borrowing requires an ordinary resolution of the body corporate at general meeting. A committee has no power to authorise it. Borrowing above the relevant per-lot threshold needs a resolution without dissent or special resolution, depending on the Regulation Module.

Is correcting a bookkeeping error the same as a fund transfer?

No. If money was genuinely misallocated to the wrong fund, a correcting journal entry is not a transfer, because the money was never properly in the correct fund in the first place.

Getting it right

The rules governing body corporate funds and borrowing in Queensland are unforgiving of shortcuts, however well-intentioned. For body corporate managers, that makes accurate record-keeping, proper resolutions, timely and honest cash flow advice to committees the difference between a scheme that runs smoothly and one that ends up in front of an adjudicator. If you have a body corporate account that has run into overdraft, or a committee asking about moving money between funds, get advice before the position becomes entrenched — it is far easier to fix a cash flow problem prospectively than to unwind an unlawful transfer or an improperly authorised borrowing after the fact.

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Shutting down discussions between lot owners at general meetings – a breach of the Strata Titles Act 1985 (WA)?

In Lenane and The Owners of Harbour Pines Strata Plan 23297 [2025] WASAT 53, SAT considered an interesting application in which various lot owners alleged that at an extraordinary general meeting (EGM), the conduct of the strata manager as the chairperson of the EGM and the council of the strata company was a breach of the strata company’s duty under section 119 of the Strata Titles Act 1985 (WA) to not act oppressively or unreasonably.

The discussions primarily related to the adoption of the 10 year maintenance plan for the strata company. Among other things, it was alleged that the floor of the EGM was held by a council member with “unhelpful rhetoric”, attempts by certain owners to make statements or ask questions on issues were blocked by the chairperson, and the EGM was conducted “with appalling railroad tactics to just push (the) vote through without any discussion”.

However, while SAT appeared to acknowledge that these allegations may have had some basis, SAT found that they ran counter to the fact that the strata company allowed for a month-long consultation period in respect of the maintenance plan and none of the relevant owners availed themselves of that opportunity. SAT found that the owners attempted a “concerted ambush” of the discussion on the merits of the maintenance plan at the EGM and the chairperson was entitled to act as she did in the circumstances.

The key takeaways for strata managers and councils are as follows:

1) Unreasonably blocking or preventing discussions between owners at general meetings could be seen as conduct which is unfairly prejudicial, oppressive or unreasonable which may be construed as the strata company acting in contravention of its duty under section 119 of the Strata Titles Act 1985 (WA); and

2) Such risk can be minimised by the strata company inviting prior consultation in respect of items listed on the agenda for a general meeting and the strata company reasonably engaging in that consultation process.

In the judgment, SAT also confirmed that the 10 year maintenance plans for strata companies do not, in and of themselves, authorise the levying of contributions on lot owners or authorise the strata company to make expenditure in accordance with the plan. The application was wholly dismissed.

If you need advice or assistance in respect of strata company or general meeting processes, do not hesitate to contact the team at Bugden Allen’s Perth office.

This article was first published on 22 July, 2026 and was written by Jonathan O’Connor, Senior Associate in our Perth office.
© Bugden Allen Group Legal Pty Ltd. This is general information only and not legal advice. You should not rely on this information without seeking legal advice tailored to your specific circumstances.