Pardoe and Pardoe (Child support)

The Administrative Appeals Tribunal (AAT) considered an application by the father, Mr Pardoe, to revoke existing percentage of care determinations made under the *Child Support (Registration and Collection) Act 1988* (Cth) concerning his two children. The mother, Ms Pardoe, opposed the revocation. The existing determinations stipulated a 65% care responsibility for the mother and a 35% care responsibility for the father.

The primary legal issue before the Tribunal was whether there had been a change to the likely pattern of care of the children since the last percentage of care determination was made, such that the existing determinations should be revoked. The Tribunal was required to assess the evidence presented by both parties regarding the actual and prospective care arrangements for the children.

The Tribunal found that the evidence did not demonstrate a material change to the likely pattern of care. While acknowledging some minor fluctuations in the children's time with each parent, the Tribunal concluded that these did not amount to a substantial alteration that would justify revoking the existing, long-standing percentage of care determinations. The Tribunal applied the principles that a change must be significant and likely to persist to warrant a revocation, and that the onus was on the applicant to prove such a change.

Consequently, the Tribunal affirmed the decisions under review, refusing to revoke the existing percentage of care determinations.