SHAN & PRASAD

In the matter of *SHAN & PRASAD*, Henderson J of the Family Court of Australia considered an application by the father to reopen parenting proceedings. The dispute concerned whether there had been a sufficient change in circumstances since the last final parenting orders were made to warrant a review of those orders.

The central legal issue before the court was the application of the principles established in *Rice & Asplund* (1994) FLC 92,177. Specifically, the court had to determine if the evidence presented by the father demonstrated a material change in circumstances that justified departing from the final parenting orders previously made by the court.

Henderson J applied the *Rice & Asplund* test, which requires a significant and material change in the circumstances of the child or the parties since the making of the final orders. The court found that the father had not adduced sufficient evidence to satisfy this threshold. Consequently, the court dismissed the father's Initiating Application filed on 18 October 2018, along with all other extant applications before it.