Satterly and Satterly (Child support)

This matter concerned an appeal to the Child Support Appeals Tribunal concerning the percentage of care arrangements for the parties' child. The appellant, Mr Satterly, sought to have the existing percentage of care determinations revoked and new determinations made, arguing that there had been a change to the likely pattern of care. The Tribunal was required to consider whether the evidence presented demonstrated a significant and ongoing change in the child's living arrangements that would justify altering the established care percentages.

The primary legal issue before the Tribunal was whether the appellant had discharged the onus of proving a change in the likely pattern of care. This involved assessing the evidence presented by both parties regarding the child's residence and the practical realities of the care arrangements. The Tribunal had to determine if the proposed new pattern of care was likely to continue for a period of at least 12 months, as required by the relevant legislation, and whether this constituted a substantial and not insignificant change from the existing arrangements.

The Tribunal affirmed the decision under review, finding that the appellant had not established a change to the likely pattern of care that would warrant revoking the existing determinations. The reasoning focused on the evidence presented, which did not demonstrate a sufficiently significant or enduring shift in the child's living arrangements to meet the legislative threshold for a new percentage of care determination. The Tribunal applied the principles governing changes to care arrangements under the *Child Support (Registration and Collection) Act 1988*, emphasising the need for clear and compelling evidence of a new, stable pattern of care.