Mankus and Matulis (No 2)

In *Mankus and Matulis (No 2)*, the Federal Circuit and Family Court of Australia considered an application by the mother for an adjournment of parenting proceedings on the morning of the hearing. The mother sought to have a Family Report prepared, despite having previously opposed such an order. The father opposed the adjournment, as did the Independent Children’s Lawyer.

The court was required to determine whether to grant the mother's application for an adjournment to allow for a Family Report to be prepared, and also whether to grant the father's application for a summary determination of the proceedings. The mother contended that a summary determination would be prejudicial and alter the existing circumstances.

Hannam J dismissed the mother's application for an adjournment, noting that the application was made on the day of the hearing and that the mother had previously opposed the preparation of a Family Report. The court also dismissed the father's application for a summary determination, finding that limited testing of the facts was necessary and that some findings would need to be made.

Consequently, the court ordered that the application for adjournment be dismissed and that the matter proceed with limited evidence as to the matters in issue.