Bloxham and Bloxham (No 2)

In the matter of *Bloxham and Bloxham (No 2)*, Foster J of the Family Court of Australia considered an application by the father for parenting orders, filed only months after final consent orders had been made. The mother sought the dismissal of this further application.

The central legal issue before the court was whether the father's Initiating Application met the threshold required to warrant further consideration, particularly in light of the recent final consent orders. This involved an assessment of the principles governing applications for parenting orders when previous final orders exist, and whether there had been a significant or relevant change in the children's circumstances since those orders were made.

Foster J determined that the father's application did not establish a significant or relevant change in the children's circumstances that would justify revisiting the final consent orders. Applying the principles established in cases such as *Rice* and *Asplund*, the court found that the threshold for entertaining a further application had not been met. Consequently, the father's Initiating Application was dismissed. Directions were subsequently made for parties to file written submissions regarding costs.