RAMSAY & RAMSAY

In *Ramsay & Ramsay*, the father was found to have contravened interim parenting orders on nine occasions. These orders stipulated that the children were to live with the mother and that the father was not to contact them for a period of three months. The father had retained the children after they left the mother's care, asserting that this action was necessary to protect their health and safety. The mother sought a recovery order for the children.

The court was required to determine whether the father had contravened the parenting orders and, if so, whether he had a reasonable excuse for his non-compliance. The court also needed to consider the appropriate course of action for more serious contraventions and whether to issue a recovery order.

Austin J found that the father had contravened the orders without reasonable excuse on nine occasions. The court determined that these contraventions fell under Subdivision F of Division 13A of Part VII of the *Family Law Act*, which deals with more serious contraventions. The court reasoned that the father's assertion of protecting the children's health and safety did not constitute a reasonable excuse for his actions. Consequently, the court dismissed the mother's oral application for a recovery order, concluding that the children should be voluntarily returned to the mother as required by the father's compliance with the orders under the imposed good behaviour bonds.

The father was ordered to enter into six concurrent good behaviour bonds for six months each, and two concurrent good behaviour bonds for twelve months each, for the proven contraventions. These bonds required the father to be of good behaviour, including compliance with all existing parenting orders. The remainder of the application-contravention was dismissed, and the mother's application for a recovery order was also dismissed.