STYLES & PALMER

In *Styles & Palmer*, Berman J of the Family Court of Australia determined final orders concerning children, property, and child maintenance. The primary dispute involved the mother's application to relocate with the parties' two children to the United Kingdom, which the father opposed. The court also addressed the division of a modest asset pool and the father's duty to maintain his non-biological son.

The legal issues before the court included whether it was in the best interests of the children to permit their relocation to the United Kingdom, the extent to which the father should maintain a meaningful relationship with them, and the reasonable practicability of such arrangements. Additionally, the court was required to determine a just and equitable division of the parties' property, considering their financial contributions and the mother's role as primary caregiver. The court also considered the father's obligation to maintain his non-biological child and the appropriate method for calculating this maintenance.

Berman J reasoned that while the mother faced emotional and financial difficulties if she remained in Australia, the children's best interests and the father's continued meaningful relationship with them were paramount. The court ultimately permitted the mother to relocate with the children to the United Kingdom, but only after a period of two years, during which specific, detailed arrangements for the children's time with the father were established. In relation to property, the court applied the principles of a just and equitable distribution, resulting in a 62.5/37.5 percentage split in favour of the husband, acknowledging his initial and ongoing financial contributions. For child maintenance, the court determined that while the legislative formula could be used as a check, it was not appropriate to apply it rigidly, ordering the father to pay $95 per week until the mother and children relocated.

The court ordered the discharge of all current orders and established equal shared parental responsibility. The children were to live with the mother at all times from August 2016, following their relocation to the United Kingdom, subject to specific periods of time to be spent with the father. The property settlement included a payment of $108,297 from the father to the mother, mutual indemnities for outstanding liabilities, and the transfer of a motor vehicle to the mother. The father was ordered to pay child maintenance of $95 per week until the children's relocation.