Entezam & Devi

In the matter of *Entezam & Devi*, the applicant sought to register an arbitral award made on 28 October 2020. The respondent advanced fifteen reasons for the Court not to register the award, arguing that these constituted "any reason" within the meaning of regulation 67Q(3) of the Family Law Regulations, which would preclude registration.

The central legal issue before Wilson J was the interpretation of the phrase "any reason" in regulation 67Q(3) and its relationship with the grounds for setting aside an arbitral award under section 13K(2) of the *Family Law Act 1975* (Cth). The Court was required to determine whether the reasons advanced by the respondent were sufficient to justify refusing the registration of the arbitral award.

Wilson J reasoned that the phrase "any reason" in regulation 67Q(3) should not be interpreted so broadly as to encompass any conceivable objection. Instead, the Court held that the reasons for non-registration must be substantial and relate to the integrity or validity of the award, akin to the grounds for setting aside an award under section 13K(2). As the respondent failed to establish any such substantial reason, the Court found no basis to refuse registration. Consequently, the arbitral award was registered pursuant to regulation 67Q(5) and section 13H of the *Family Law Act*, and it was ordered to have effect as if it were a decree made by the Court.