Rainford and Channing (Child support)

This matter concerned an appeal by the father, Rainford, against a decision of the Child Support Registrar concerning the assessment of child support payable to the mother, Channing. The dispute centred on the percentage of care provided by each parent, particularly whether a period of overseas travel by the child had altered the established pattern of care. The appeal was heard by P Jensen M.

The primary legal issue before the court was whether the Registrar had erred in determining that the percentage of care had not changed, despite the child's absence from the father's care for a period of approximately six weeks due to overseas travel. This required the court to consider the definition of "change in the pattern of care" within the framework of the *Child Support (Registration and Collection) Act 1988* (Cth) and relevant case law.

The court affirmed the Registrar's decision, finding that a temporary absence due to overseas travel did not constitute a change in the overall pattern of care as contemplated by the legislation. The reasoning applied was that the travel was a temporary disruption to the established care arrangements, rather than a fundamental alteration to the long-term or habitual care arrangements between the parents. The court emphasised that for a change in the pattern of care to be recognised, it must be more substantial and enduring than a short-term absence.