Practice Direction No. 46A

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Guidelines for Expert Witnesses in Proceedings

in the Supreme Court of South Australia

 

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| general duty to the Court | form of expert report |

| further obligations of an expert and the party retaining the expert |

| expert’s evidence | consequences of non-disclosure |

| experts’ conference | experts employed by a party to the action |

 

1.      These guidelines apply to all actions in which the pleadings have closed on or after 3 June 2000.

 

2.      These guidelines are not intended to address exhaustively all aspects of an expert’s report and an expert’s duties.

 

3.      These guidelines, however, must be complied with for an expert to comply with r 38.01A(2)(d).

 

4.      General duty to the Court:

          4.1  An expert witness has an overriding duty to assist the Court on matters relevant to the expert’s area of expertise.

          4.2  An expert witness is not an advocate for a party.

          4.3  An expert witness’s paramount duty is to the Court and not to the person retaining the expert.

 

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5.      The form of the expert report:

          5.1    An expert’s written report will set out with reasonable particularity all of the qualifications of the expert which are relied upon to qualify the expert to give the report.

          5.2    It will set out separately all of the factual findings or assumptions upon which any opinion is based.

          5.3    The report will give particulars identifying the material upon which the expert bases his or her expert opinion.

          5.4    If any tests or experiments are relied upon by the expert in compiling the report, the report should contain details of the qualifications of the person who carried out any such tests or experiments.

          5.5    Where an expert’s report refers to photographs, plans, calculations, analyses, measurements, survey reports or other extrinsic matter, these must be provided to the opposite party at the same time as the delivery of the report.

          5.6    The report should set out separately from the factual findings or assumptions each of the opinions which the expert expresses.

          5.7    The expert should give reasons for each opinion.

          5.8    If an expert opinion is not fully researched because the expert considers that insufficient data is available - or for any other reason, this must be stated with an indication that the opinion is no more than a provisional one.  Where an expert witness who has prepared a report believes that it may be incomplete or inaccurate without some qualification, that qualification must be stated in the report.

          5.9    The expert should make it clear when a particular question or issue falls outside his or her field of expertise.

          5.10  The expert’s report will contain an acknowledgement at the commencement of the expert’s report that the expert has been provided with this practice direction prior to preparing the expert’s report and that the expert has read it and understood it. 

          5.11  At the end of the report the expert should declare that (the expert) has made all the inquiries which “(the expert) believes are desirable and appropriate and that no matters of significance which (the expert) regards as relevant have, to (the expert’s) knowledge, been withheld from the Court.

 

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6.      The further obligations of an expert and the party retaining the expert:

          6.1  If, after exchange of reports or at any other stage, an expert witness changes his or her view on a material matter, having read another expert’s report or for any other reason, the change of view should be communicated in writing (through legal representatives) without delay to each party to whom the expert witness’s report has been provided and, when appropriate, to the Court.

          6.2  The party who has retained the expert will, if requested by a party to whom an expert’s report has been delivered, deliver to that party:

                 6.2.1 a list of all documents which have been referred to, or prepared by or at the direction of the expert in the course of preparing the report.

                 6.2.2 copies of any documents in the list delivered pursuant to 6.2.1.

                 6.2.3 details of any fee, disbursement or benefit received, or receivable, by the expert or anyone on his or her behalf, for the preparation of the report and for services provided, or to be provided, by the expert or by any one on his or her behalf in connection with the expert giving evidence for the party in the action;

                 6.2.4 a list of all conversations in which the expert has taken part with any party, any legal representative of a party or any other expert consulted in relation to the matter relevant to the opinions expressed in the report stating when and with whom each such conversation occurred and the topics discussed;

                 6.2.5 copies of all notes made by or on behalf of the party or by or on behalf of the expert concerning any of the conversations referred to in a list provided under the previous obligation.

 

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7.      The expert’s evidence:

          An expert’s evidence in chief at the trial unless the Trial Judge otherwise allows is to be given only by tendering the reports from the expert which comply with r 38 and the expert swearing that the reports are correct.

 

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8.      Consequences of non disclosure:

          If a party fails to comply with the Rules of Court or this Practice Direction in respect of an expert’s report:

          8.1  The Court may adjourn the hearing or trial at the cost of the party in default or his or her solicitor.

          8.2  The Court may direct that evidence from that expert not be adduced by that party at the trial in the action.

          8.3  The Trial Judge may award costs to the other parties or reduce costs otherwise to be awarded to the party in default.

          8.4  The Trial Judge may take that failure, if it be by a plaintiff, into account in assessing the award of damages to the plaintiff.

 

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9.      Expert’s conference:

          9.1  If experts retained by the parties meet at the direction of the Court, or at the request of solicitors for the parties it would be improper conduct for an expert to be given or to accept instructions not to reach agreement.  If, at a meeting directed by the Court, the experts cannot reach agreement on matters of expert opinion, they should specify their reasons for being unable to do so.

 

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10.    Experts employed by a party to the action:

          The provisions and requirements of r 38 and this Practice Direction apply to any person called as an expert in the action, even if the expert is employed by a party to the action.

 

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DATED 17th May 2002.

 

 

                                                                            (Ruth Blenkiron)

                                                                            REGISTRAR