GADHAVI & GADHAVI

FAMILY COURT OF AUSTRALIA

GADHAVI & GADHAVI

[2019] FamCA 326

FAMILY LAW – CHILDREN – Where the wife seeks sole parental responsibility – Where the husband seeks equal shared parental responsibility – Where there are serious allegations of family violence made against the husband by the wife and child – Where the child is 16 years of age –Where the child’s view is that she does not want to spend time with the husband – Where the Court gave consideration to the views of the child – Orders made for the wife to have sole parental responsibility pending further order – Child to live with the wife – No order for time with the husband – Orders made to restrain the husband from contacting or communicating with the child through any means

FAMILY LAW – INJUNCTION – Where the wife seeks an order for exclusive occupation of the former matrimonial home – Where the wife seeks various injunctions to give effect to the exclusion of the husband from the home – Where at the time of separation the wife was living in the home with the child and the husband was away from the home – Where there is considerable dysfunction and conflict between the parties – Where it was not reasonable, sensible or practicable that the parties be required to live together – Orders made for the wife to have exclusive occupancy of the home – Orders made for the husband to be restrained from attending the property or approaching or communicating with the wife or child

Family Law Act 1975 (Cth) s 60CC

Davis & Davis (1983) FLC 91-319
Page & Page (1981) FLC 91-025
Price & Price (Unreported, Family Court of Australia, Lindenmayer J, 2 July 1982)

APPLICANT:

Ms Gadhavi

RESPONDENT:

Mr Gadhavi

INDEPENDENT CHILDREN’S LAWYER:

Ms Webber

FILE NUMBER:

SYC

7722

2018

DATE DELIVERED:

25 March 2019

PLACE DELIVERED:

Sydney

PLACE HEARD:

Sydney

JUDGMENT OF:

Johnston J

HEARING DATE:

25 March 2019

REPRESENTATION

COUNSEL FOR THE APPLICANT:

Mr Campton SC

SOLICITOR FOR THE APPLICANT:

Broun Abrahams Burreket

COUNSEL FOR THE RESPONDENT:

Mr Hodgson

SOLICITOR FOR THE RESPONDENT:

O'Sullivan Legal

SOLICITOR FOR THE INDEPENDENT CHILDREN’S LAWYER

Ms Webber, Legal Aid NSW

Orders

That pending further order as from 14 days from today the wife be entitled to the exclusion of the husband to reside in E Street, Suburb H and the husband be and is hereby restrained from attending the property, approaching the wife or X or communicating with the wife or X directly or indirectly by any means other than through his legal representatives.
That orders be made in accordance with the handwritten draft Minutes of Order filed in Court today, signed by me and placed with the Court papers as set out hereunder:
1.That the husband deliver to the solicitors for the wife on or before 8 April 2019:
1.1    all keys for external and internal doors of the home; and
1.2    all keys and remotes to the windows, blinds and louvres.
2.That the husband do all things as are necessary to vacate the home in a clean and tidy condition.
3.That the husband be restrained from doing any act or thing to:
3.1    cancelling any utility services to the home;
3.2    removing any furniture or personalty from the home except for:
a)the furniture in the main bedroom;
b)desk, computers and personal files of the husband in the study;
c)the husband’s clothing and personal effects.
That orders be made to continue pending further order in accordance with the Minute of Orders proposed by the Independent Children’s Lawyer filed in Court today contained at Exhibit “1”, signed by me and placed with the Court papers as set out hereunder:
1.That the mother have sole parental responsibility for the child, X born …2003 (“X”).
2.That X live with the mother.
3.That there be no order for X to spend time with the father.
4.That the father is hereby restrained by injunction from:
(a)    Contacting or communicating with X in any way, including by but not limited to, telephone, text message, email or other correspondence or by social media or through the intervention of a third party;
(b)    Contacting or communicating with X’s school and medical and health practitioners;
(c)    Attending X’s school or any school, sport or extra-curricular event or activity to which parents are invited;
(d)    Attending upon any medical or allied health practitioner from whom X is receiving treatment;
(e)    Posting any photograph or other information about X on social media, including but not limited to any communications with the father which the father may have received or may in the future receive from X;
(f)     Approaching X or remaining within 50 metres of X.
5.That each parent is hereby restrained by injunction from denigrating the other parent or speaking in a derogatory or insulting way about the other parent in X’s presence or hearing.
6.Each parent shall use their best endeavours to ensure that no third party denigrates the other parent or speaks in a derogatory or insulting way about the other parent in X’s presence or hearing, and if such conduct continues to occur the parent shall immediately remove X to a place where she cannot hear the conversation.
7.That as soon as reasonably practicable, the mother inform the father by text message if X suffers any serious illness or medical emergency.
That all costs be reserved.
The Court notes that in the event that the husband proposes to take occupation of the Region D property the wife will make keys available to him for this purpose.

Note: The form of the order is subject to the entry of the order in the Court’s records.

IT IS NOTED that publication of this judgment by this Court under the pseudonym Gadhavi & Gadhavi has been approved by the Chief Justice pursuant to s 121(9)(g) of the Family Law Act 1975 (Cth).

Note: This copy of the Court’s Reasons for Judgment may be subject to review to remedy minor typographical or grammatical errors (r 17.02A(b) of the Family Law Rules 2004 (Cth)), or to record a variation to the order pursuant to r 17.02 Family Law Rules 2004 (Cth).

FAMILY COURT OF AUSTRALIA AT SYDNEY

FILE NUMBER: SYC 7722 of 2018

Ms Gadhavi

Applicant

And

Mr Gadhavi

Respondent

EX TEMPORE REASONS FOR JUDGMENT

These are interlocutory proceedings. There are two aspects to these proceedings. Firstly, there are certain parenting orders sought on an interim basis in relation to the child X who was born in 2003, and who is 16 years of age.
The other major area of disputation which the parties have brought to the Court for determination today is in respect of occupancy of the former matrimonial home.
On the one hand, Ms Gadhavi (“the wife”) seeks an order that pending further order she be entitled to the exclusion of Mr Gadhavi (“the husband”) to reside in the former matrimonial home. To facilitate that order, an injunction be granted to restrain the husband from attending the property, approaching the wife or X or communicating with the wife or X directly or indirectly by any means, including by any third party or agent on the husband’s behalf or by any social media platform.
Turning to the parenting aspect, there is no issue about the parenting arrangements that should be put in place in the interests of X in terms of her residence. This is because the wife is seeking an order that she live with the wife. The husband is not opposing that order. That seems to be an acknowledgement of the current situation which is that X has always lived with her mother.
This matter came before me on 6 February 2019 and my recollection is that there was insufficient time to hear the proceedings. The matter came before me in a busy duty list and therefore I adjourned the matter for an interim hearing today. On 6 February I made certain orders on a without prejudice and without admissions basis pending further order.
Those were orders that the child live with her mother and that there be no order for time spent by the child with the father. There were also some restraints. These were that the father be restrained by injunction from contacting or communicating with X including by, but not limited to, social media either directly or indirectly or by way of a third party, contacting or communicating with X’s school and medical or health practitioners, attending X’s school or any school sport or extracurricular or social activity or posting any photo or other information about X on social media.
An order was also made that the mother notify the father in writing as soon as possible about any serious illness suffered by the child or needing treatment administered to the child. Certain procedural orders were made in the form of directions for readying the matter for hearing today. I understand from the parties that those orders have been respected and that is the situation which has prevailed to the present time.
The husband does not oppose X continuing to live with her mother pending further order.
He does not oppose an order which would enable the child to be able to go overseas with her mother or as otherwise directed. But what is opposed is an application by the wife that the wife be given sole parental responsibility for X.
The child has appointed for her an Independent Children’s Lawyer (“ICL”). Ms Webber is assisting today in that capacity. Ms Webber has given to each of the parties and to the Court a draft minute of orders proposed by the ICL.
I think it is fair to say that those orders line up with the orders which are sought by X’s mother. That is, the ICL is seeking an order that the mother have sole parental responsibility for the child, that the child live with the mother, that there be no time spent between X and her father, and the restraints which I have already referred to including a non-denigration additional restraint. All these orders are pending further order

Background

The husband was born in 1957.
The wife was born on in 1964.
The parties commenced cohabiting upon their marriage in 1998 and they separated on 20 July 2018.
There are two children of the marriage, firstly, Mr B who was born in 2000, and who is now an adult, and the child in respect of whom these parenting orders are sought, X, who was born in 2003.
Separation occurred in most unfortunate circumstances where there had been an argument, allegedly an incident, between the parties. A provisional Apprehended Domestic Violence Order (“ADVO”) issued on that occasion for the protection of the wife. In those circumstances, the husband ceased to occupy the former matrimonial home.
Subsequently there was a variation of that order and ultimately that ADVO was discharged. But what has occurred in respect of occupancy of the former matrimonial home is that the husband ceased to occupy the home so the wife and the two children continued to reside there until mid-November 2018 when X went to Country C. She had been offered a selective school exchange in Country C, and she was accompanied by her mother. Mr B remained living in the former matrimonial home in their absence overseas.
During the absence of the wife and X from the former matrimonial home, the husband moved back into the home, and there was an exchange of correspondence. Mr Hodgson who was acting for him at the time wrote to the wife’s solicitors informing them that the husband had reoccupied the former matrimonial home. In those circumstances, Mr B, as I understand it, vacated the home, and he has not returned to the home since that time.
There are many allegations made by each of the parties against the other. There are very serious allegations made by the wife against the husband about serious family violence. I am not going to go into the details of those except to say that there are various allegations made of pushing and hitting, poking the wife in her cheek really hard and pushing her downstairs. There are also numerous allegations of verbal abuse, psychological abuse, controlling behaviour, assault and assaulting the vehicle when the parties were driving. It is not clear to me what the actual situation is in relation to those allegations.
There is evidence about things said by X to her treating clinical psychologist, Ms F, and there is other material in which allegations of violence are made. But what is very clear to me is that the behaviour within this family, by both parents, certainly by Mr B, I do not know about X’s behaviour, but there has been an abundance of behaviour from which one could characterise this family as being quite dysfunctional. It is very clear that the parents have a very poor relationship.
There has been a lot of conflict and hostility between the parents and much of that conflict and hostility has unfortunately been acted out in front of the children. This might say something about how Mr B is alleged to have behaved which seems to have caused considerable difficulty within the family. Just to provide an illustration of the conflict between these parents because I think it is really important in relation to the issue of parental responsibility for X. I note that on 14 July 2018, the husband sent the wife the following email message:
You have persecuted me for 20 years – Mr J [whom I think is a psychiatrist] said that it was a tribute to my mental fortitude that I didn't have a breakdown earlier - have some fucking contrition and learn some manners attention seeking grandstanding scum of related parents - how dare you do this to me.
And stop me from seeing X tomorrow and you will regret it - I don’t want to see your whinging face…
This was directed to the mother of the husband’s children. It concerns me that a parent could speak in such incredibly disrespectful terms to the other parent. Mr Hodgson suggested to me that that was just intemperate language on the part of the husband in circumstances where his world has been broken down since July. Unfortunately, this is not an isolated message and not an isolated example of the way the husband speaks to the wife. There are many examples which are contained in email correspondence, not just allegations by the wife, and they accord with the wife’s allegations.
To continue this example, the wife responded:
Please do not come tomorrow - X is distraught with the conflict - she needs a break, we all need a break…
To finish off this example, the husband responded as follows:
Fuck off - you created the conflict - go and see a psychiatrist - stop me seeing X and I will take action.
It is not only the husband who is capable of this incredibly disrespectful and grossly offensive language but also the wife, at least, on the husband’s allegations. I accept that it is untested at this point, but the husband alleges that the wife has often made disparaging remarks about him which included the following:
Your parents were related, that’s your problem.
You are a little man with a little dick.
Your academic transcripts are fake.
You are an idiot.
You are average in your profession and I am top of mine.
There is so much evidence of conflict and hostility between the parents, where the whole family have been in therapy, which broke down by about 2015 and where X, at least, on my reading of Ms F’s material and notwithstanding what is submitted on behalf of the husband, is in considerable psychological difficulty, that it would hardly be a surprise to hear allegations along those sorts of lines.
What I am asked to do is determine whether this Court ought to leave the parental responsibility as shared parental responsibility, shared by each of the parents as it exists under the law. I do not think there has been an order made in respect of parental responsibility. Apart from the order that I made on 6 February 2019, I do not think that situation has been changed.
What one would say in favour of joint parental responsibility and what all the experts say who come and give evidence in these cases frequently and regularly, is that for joint or equal shared parental responsibility to be able to work requires a considerable co-operative effort by each of the parents and, at least, a reasonable level of being able to communicate. In this case, the evidence in my view, demonstrates anything but that. I have already referred to the conflict and hostility between the parents and I have given some examples of that.
When the Child Dispute Conference memorandum was prepared following interviews of the family, what the Family Consultant said, and this was actually on 6 February 2019 when I put in place the order for sole parental responsibility to the wife, at least, on a limited basis, the family consultant said:
·There is no co-parenting relationship and the parents are seemingly entrenched in considerable conflict.
·The parents currently communicate via their legal representatives.
·The parents present diametrically opposing accounts of their relationship.
And then, as noted previously:
… [X] is in the midst of serious parental conflict, which can result in psychological difficulties, such as emotional, behavioural and other problems…
I omitted to mention that the other parenting order which is sought by the husband is that X spend time with him in accordance with her wishes. I think that is his position.
To determine what is in the best interests of a child, the primary considerations are set out in subsection 60CC(2) of the Family Law Act 1975 (Cth) (“the Act”). These are firstly:
(a)the benefit to the child of having a meaningful relationship with both of the child's parents, and
(b)the need to protect the child from physical or psychological harm from being subjected to, or exposed to, abuse, neglect or family violence.
Subsection 60CC(2A) of the Act requires the court in applying these considerations to give greater weight to the latter consideration.
And this goes to the issue of the child spending time with the father in accordance with her wishes and also the mother’s application that the child spend no time with the father.
The additional considerations are set out in subsection 60CC(3) of the Act. The first of those is:
Any views expressed by the child and any factors (such as the child’s maturity or level of understanding) that the court thinks are relevant to the weight it should give to the child’s views.
There is some controversy about the child’s views. There are very strong submissions and evidence put by the wife and also by the ICL that X has very clearly indicated that she does not wish to spend any time with the father, and that she does not want to have any contact with him.
I note that on Christmas Day 2018, X informed the husband that she hoped he had a nice Christmas but asked him not to contact her, and that she did not want to see him. The husband responded that he did not wish to see her either while she behaved like that. I am satisfied on the basis of Ms F’s material that the child suffered distress as a consequence of receiving that message from the father.
The mother refers to numerous instances where she said that X has expressed to her views of not wanting to spend any time with her father. She said in her affidavit filed 30 January 2019 that X said to her words to the following effect:
I do not wish to spend any time with Dad.
I am scared of Dad, I have nightmares about him.
I am also worried Dad will contact my school or my friends and embarrass me.
I am worried Dad will turn up to school or my after school activities.
I am worried that Dad will hurt you and Mr B.
I woke up from a nightmare again - I thought Dad had hurt you and Mr B.
Ms Webber has had three meetings with X. She said that what X said to her during the course of those meetings was consistent with what the mother and Ms F had reported, namely, that she did not want to see her father. Ms Webber submitted that the child is 16 years of age she is a very clever girl and that is borne out by the fact that she has been selected for the placement under the arrangements with G University and that the Court, in all the circumstances, should give considerable weight to her views.

I have referred to Ms F, who is a clinical psychologist, whom X has been consulting since 10 August 2018. X was referred to Ms F by the Victim Services Support Scheme of the New South Wales Department of Justice.
X reported to Ms F multiple incidents of domestic violence at the hands of her father. I am not going to go into the details of those but they are along the lines of the matters that I have already referred to.
X, and this is in the report, informed Ms F that she does not wish to spend any time with her father because she feels unsafe in his company. She feels he is lying and is constantly trying to trick her and twist her words.
Ms F reported that X presents with symptoms of post-traumatic stress. Her symptoms are said to include severe flashbacks and reliving the aggression and violent assaults on her, her mother and brother. Ms F reported that X said she was having ongoing nightmares about her father hurting her mother and her brother.
Ms F said that X displays feelings of extreme hopelessness and helplessness with raised levels of frustration, stress and anxiety relating to her family circumstances.
Those expressions her views are put in issue to some extent by the husband. He says that there have been a series of text messages and some other behaviours by X towards him which make him think that she cannot have been telling Ms F the truth. In particular, I have had the benefit of reading numerous text messages. In November 2018, the first which is on 20 November 2018, the text is as follows:
hi dad
just letting you
know i am
completely fine.
lots of love
[X]
and that I understand came when the child was overseas undertaking the exchange program last November.
Then again on 21 November 2018, "hi dad," and then later that day:
hello daddy
got a sim with
unlimited data so
got a number
change
and is obviously sending her father the telephone number.
And then a few days later on Saturday 24 November 2018, a text message to dad:
yummy! thanks
daddy for
forwarding exam paper…
And then on 10 January 2019:
dad i just saw your
email - are you
ok?? i'm sitting my
driving test today
so just studying
now and then
going to the test
but when i get
back i'll text you to
discuss my trip -
it’s really important.
And then later on the same day:
dear dad
i’m really worried
that you hit your
head - are you
ok??
i just got back
from getting my Ls (which is presumably learner's permit)
and passed my
test this afternoon.
I just really want to…
On 12 January there was a further exchange as follows:
…
thank you so
much daddy i
really appreciate
it!!! thank you
thank you i
promise will call
you when i get
there
And my understanding that relates to the proposed overseas visit in January, "thank you thank you" and there are lots of emojis which are love hearts:
thank you thank
you
i really appreciate
it because this is
so important to me!!
[more emojis, love hearts] this
makes me so
happy
All of this on 12 January:
thank you so
much for giving
consent daddy –
see you when i get
back
And then a text message from father to X, “Safe flight darling.”
It is said that those text messages raise concerns about what the child’s views actually are. I am not persuaded that this Court would make a finding about the views of the child which is other than what has been put both by the mother and by the ICL.
Those texts occurred at a time, of course, when the child was wanting to be able to go overseas. It may be possible that the child is endeavouring to live two lives in extremely difficult circumstances in the dysfunctional family situation in which she finds herself and about which she expressed such hopelessness and helplessness.
I accept that at three meetings with her own lawyer she has continued to express a view consistent with what she said to her therapist, Ms F, and consistent with what her mother is saying. In my view, this is more likely than not to represent the child’s current views.
Whether the Court ought to give weight to her views, I would accept the submissions by Ms Webber in relation to that. After all, X is 16 years of age and, as I say, she is an intelligent girl who is doing remarkably well, certainly, in an academic sense and in her scholastic pursuits. This Court rarely makes orders for 16 year olds for the obvious reason. By 16, generally, we respect what 16 year olds are saying. To the extent that there might be a submission that all this is put up by the mother to the 16 year old child, and that the Court would be really concerned about accepting her views, I would not accept that submission.
So we have a situation in relation to the parenting orders sought where we have this dysfunctional relationship between the parents where not only can they not really communicate but when they communicate it is in the incredibly disrespectful terms to which I have referred. We have a situation where the child is expressing, in my view, a clear view that, in the circumstances in which she finds herself, for whatever reason, she has decided at the moment that she is not going to have contact with her father.
I accept, at this interim stage and in the absence of an opportunity for deeper exploration and investigation and an opportunity for more detailed professional behavioural science opinion about that, in all the circumstances, the parenting orders sought by the mother and by the ICL are orders which, in my view, will serve at least in the interim, the best interests of the child.
I move from that matter to the question about exclusive occupancy of the home. I have been addressed about the law in respect of this matter and nothing has been said which takes me away from my understanding about the law that is to be applied. This is what was said by Lindenmayer J a very long time ago, in an unreported decision of Price & Price (which judgment was delivered on 12 July 1982), where his Honour , extracted from Page & Page (1981) FLC 91-025, the relevant principles of law in relation to applications for exclusive occupation of a matrimonial home which principles his Honour encapsulated in the following paragraph:
In my opinion, Page’s case demonstrates a softening of the Court’s attitude towards applicants for exclusive occupation orders. It seems to indicate that it is no longer necessary that such an applicant show that it is impossible or intolerable for him or her to continue in co-occupation of the house with the other party, or that there has been some conduct by the other party which justifies his exclusion from the home. All that is necessary, it seems, is that the Court should regard the situation between the parties as being such that it would not be reasonable or sensible or practicable to expect them to continue to remain in the home together.
Baker J in the Full Court decision of Davis & Davis (1983) FLC 91-319 referred to Price and said at 78,170:
This passage, in my view, correctly states the principles of law to be applied in applications for exclusive occupancy of a matrimonial home.
There is more than perhaps one part to the thrust of the submission on behalf of the husband about this. His proposal, firstly, is that the parties would not be living in the same home. What he proposed, and he has helpfully presented the Court with a plan of the former matrimonial home is that he would live in a separate part of the home so that the wife and children would be able to live in the main part of the home, and he would live downstairs in a separate part of the home.
The second part of the submission on behalf of the husband is that the Court is entitled to consider the conduct of an applicant for this sort of injunction and what an applicant cannot do is seek to obtain an injunction in circumstances where they have brought about the very situation in respect of which they are then asking the Court to regulate by way of making an injunction. It was submitted on behalf of the husband that it is the wife who has brought about this situation, that she is causative because she made a decision to bring the marriage to an end on 20 July 2018, that she made a report to the police which had the consequence of the police putting in place a provisional ADVO which was subsequently discharged, and that it is the wife who brought about this situation that a provisional ADVO having as a consequence the removal of the husband from being able to occupy the home and, in all those circumstances, it is submitted that the wife’s behaviour in doing those things has to be considered.
I reject that submission. I do not have a view that this is a case where the Court would be persuaded that the wife has acted in such a way as to bring about the circumstances which she now seeks to use to her advantage. What the Court must determine is whether it is reasonable, sensible and practicable for these parties to be expected to be able to continue to remain in the matrimonial home.
So far as the husband’s suggestion that we put in place orders which would confine each of the parties to specific physical parts of the property is concerned, given the appalling state of the relationship of the parties and their dreadful behaviour and in the light of Ms F’s report about the effect that the conflict and the hostility are having on X and the circumstances in which she finds herself, in my view, that would hardly be a reasonable situation.
If the Court was to put in place that sort of arrangement, in my view, that would almost certainly just involve everybody coming back to the Court for further injunctions. I would have no confidence whatsoever that these parents would be able to behave in relation to one another in a manner which would not involve the sort of behaviour that had been ongoing now for many years. So, in my view that is not an appropriate position.
It would not be reasonable, sensible or practicable to expect them to continue to live in those sorts of circumstances. What the Court needs to do is to consider all the other factors which are generally called balance of convenience matters, but it is really a broader issue than balance of convenience. One looks at all those relevant factors but one also have to make a determination about whether the order is proper and also whether such an order is just in all the circumstances.
Turning to those balance of convenience matters. It is relevant that at the time that the parties separated the wife and children were living in the home and the husband was out of the home. It is relevant, in my view, to consider, as I have said, the considerable dysfunction and conflict between the parents.
It is also relevant to consider the children’s, and particularly X's, exposure to the ongoing conflict and dreadful behaviour probably by both of her parents.
Each of the parents have sufficient funds to be able to provide accommodation for themselves away from the home. This, of course, has been the position in which the wife and children have been living since the wife and then some little time later X returned from Country C. They have had various modes of accommodation since that time and numerous changes to accommodation since that time.
The wife and both children are currently living at a hotel in Suburb K. Clearly, the wife would have the means to be able to accommodate herself and the children which would provide for their physical needs, and the husband is in a similar situation.
Each parent has access to a very considerable amount of money, in fact, cash which they could use to fund accommodation. Each of the parents also would have access to the property that the parties have which is a holiday home on the Region D. The logistics of trying to get X from the Region D to L School every day for school would involve, in my view at least, a degree of difficulty. On the other hand, the husband could have access to that property. The husband does not work and he has not worked for many years.
The former matrimonial home is close to X’s school. She has friends in the area, her school is in the area, and one would expect it to be easier for her to attend her extracurricular activities by her being in her usual home.
In my view, when one considers all the relevant factors that go to convenience or lack of convenience and hardship, I accept the submissions on behalf of the wife that they clearly favour the wife. It would be in X’s interest to be back in her own home, to be close to her school. I accept that she has real psychological challenges at the present time and one would expect for her to be back in her own home in her own bedroom with her own things and her friends in the area, are matters highly relevant in the consideration of those balance of convenience factors.
So far as the order being proper is concerned, in my view, such an order would be proper and just in all the circumstances.
So I propose to put in place orders in terms of the parenting as sought by the ICL, and in respect of the occupancy, counsel for the wife has prepared some machinery orders.

I certify that the preceding seventy-four (74) paragraphs are a true copy of the reasons for judgment of the Honourable Justice Johnston delivered on 25 March 2019.

Associate:

Date: 22 May 2019

[2019] FamCA 326

25 March 2019

Key Legal Topics

Areas of Law

Family Law

Equity & Trusts

Legal Concepts

Injunction

Procedural Fairness

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Jurisdiction