Salmon and Salmon & Ors (No 2)

In *Salmon and Salmon & Ors (No 2)*, Carew J of the Family Court of Australia considered an application by the husband, joined by the second and third respondents, for permission to rely on a further expert report concerning an issue already addressed by a court-appointed single expert. The wife’s estate opposed this application.

The central legal issue before the court was whether the husband had established a "special reason" to justify the appointment of a second expert witness, pursuant to rule 15.49 of the *Family Law Rules 2004* (Cth), when a single expert had already been appointed by the court to report on the same matter.

Carew J dismissed the husband's application, finding that he had not demonstrated the necessary special reason to depart from the usual practice of relying on a single expert. The court reasoned that the existing expert report was intended to provide clarity on the issue, and the rules provided mechanisms for parties to seek clarification through conferences or written questions. Consequently, the court made orders extending the time for the parties to confer with the single expert or to submit questions to clarify the existing report, while dismissing the application for a new expert report.