Raider and Raider (No 2)

In *Raider and Raider (No 2)*, Forrest J considered allegations of contempt against the mother for contravening court orders. The central dispute revolved around whether the mother's conduct demonstrated a serious disregard for her obligations under the primary orders, which would trigger the application of specific provisions within the Family Law Act 1975 (Cth) concerning contempt.

The court was required to determine the appropriate legal framework for dealing with the mother's alleged contraventions and, consequently, what penalty, if any, should be imposed. Specifically, the court had to decide whether the mother's behaviour warranted treatment under provisions requiring a finding of serious disregard of obligations, or if other provisions were applicable.

Forrest J found that the mother's contraventions did not demonstrate a serious disregard of her obligations under the primary orders. Consequently, the court determined that the mother should be dealt with under the provisions of subdivision E of Division 13A of Part 7 of the Family Law Act 1975 (Cth), rather than subdivision F. The court considered that an appropriate penalty for the mother, in these circumstances, was an order to attend and complete a post-separation parenting orders program. The father was also ordered to attend such a program and an anger management program. The matter was referred for case management until trial ready, with the trial to be listed only after both parties had completed their respective programs.