Henley and Henley

In *Henley and Henley*, Stevenson J considered an application by the father to re-open final parenting orders made on 19 August 2018. The father sought to vary these orders, which had been previously made by Berman J.

The central legal issue before Stevenson J was whether the father had established sufficient changed circumstances, or a previously undisclosed fact, to justify re-opening the final parenting orders. This required the court to assess the evidence presented by the father against the threshold for re-opening final orders in family law proceedings.

Stevenson J found that the father had failed to demonstrate the necessary changed circumstances or previously undisclosed fact. Consequently, the court was not satisfied that it should re-open the final parenting orders, except to the limited extent previously ordered by the Full Court on 20 July 2017. The proceedings were then referred to Austin J for further case management.