Rodham and Orpen (Child support)

This matter concerned an appeal to the Full Court of the Family Court of Australia regarding child support assessments. The parties, Rodham and Orpen, were involved in a dispute over the percentage of care arrangements for their child. The primary issue was whether there had been a change to the likely pattern of care, which would necessitate a review and potential revocation of existing percentage of care determinations. The court also considered whether reasonable action had been taken by a parent in response to non-compliance with court orders concerning care arrangements, and the application of an interim period.

The legal issues before the Full Court were whether the Registrar of the Child Support Agency had erred in revoking existing percentage of care determinations and making new ones, and whether the Registrar had correctly applied the relevant provisions of the *Child Support (Registration and Collection) Act 1988* (Cth) concerning changes to the pattern of care and reasonable action taken by a parent. The court was required to determine if the evidence supported a finding that the likely pattern of care had changed sufficiently to warrant the revocation and reassessment, and if the Registrar’s decision was otherwise legally sound.

The Full Court affirmed the decision under review. The court reasoned that the Registrar had correctly identified a change in the likely pattern of care, justifying the revocation of the existing determinations. The court also found that the Registrar had properly considered the actions of the parties in relation to compliance with court orders and had applied the provisions for an interim period appropriately. The principles applied centred on the statutory requirements for varying child support assessments based on changes in care arrangements and the Registrar's powers to make such variations.