BOWEN & SAWER

In the matter of *Bowen & Sawyer*, Austin J of the Family Court of Australia considered applications concerning contraventions of existing parenting orders and proposed variations to those orders. The father was found to have contravened the court's orders on three separate occasions without reasonable excuse. The mother sought variations to the final orders made in July 2017, including a proposal to suspend the child's visit with the father for a specific weekend, which was ultimately not granted due to a lack of changed circumstances. The father also sought variations, including a reversal of the child's residence and restrictions on the mother's contact with her partner, but these were also dismissed.

The central legal issues before the court were whether the father had contravened the parenting orders, and if so, how those contraventions should be dealt with under the Family Law Act 1975 (Cth). The court was also required to determine the merits of the parties' respective applications for variation of the existing final orders.

Austin J reasoned that the father's contraventions were established and should be addressed under Subdivision F of Division 13A of Part VII of the Family Law Act. The court determined that the father's applications for variation of the final orders lacked sufficient grounds, particularly the proposed reversal of residence and the requested restraint orders against the mother. Consequently, the court ordered the father to enter into concurrent good behaviour bonds for a total duration of six months, commencing from the date of entry. Furthermore, the father's time with the child was suspended until the latter of his entry into the good behaviour bonds or a specified time on a subsequent day. The father was also ordered to pay the mother's costs for the enforcement hearing in the sum of $1,500.