Federal Circuit and Family Court of Australia
(DIVISION 1)
Swinbank & Stein [2022] FedCFamC1F 682
File number(s): CSC103 of 2021 Judgment of: JARRETT J Date of judgment: 14 September, 2022 Catchwords: FAMILY LAW – Application for declarations pursuant to s.90RD of the Family Law Act 1975 (Cth) – whether the parties were in a de facto relationship – where the applicant bears the evidential and legal burden – where neither party were credible witnesses – where the parties share two children – where the evidence permits a finding that the parties were in a relationship – where the paucity and quality of both parties’ evidence, including the applicant’s, does not permit finding that the parties were a couple who lived together on a genuine domestic basis Legislation: Family Law Act 1975 (Cth) ss 4AA, 90RD
Evidence Act 1995 (Cth)
Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) r 1.31
Cases cited: Fairbairn v Radecki [2022] 96 ALJR 529; HCA 18
Onslow & Onslow [2016] FamCAFC 7
Sinclair & Whittaker (2013) FLC ¶93–551; [2013] FamCAFC 129
Division: Division 1 First Instance Number of paragraphs: 108 Date of last submission/s: 21 June, 2022 Date of hearing: 20 & 21 June, 2022 Place: Cairns Counsel for the Applicant: Mr Lenehan Solicitor for the Applicant: Sharma Lawyers Counsel for the Respondent: Ms Carmody Solicitor for the Respondent: Aylward Game Solicitors ORDERS
CSC103 of 2021 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 1)
BETWEEN: MR SWINBANK
Applicant
AND: MS STEIN
Respondent
order made by:
JARRETT J
DATE OF ORDER:
14 September, 2022
THE COURT DECLARES THAT:
1.Pursuant to s 90RD(1) of the Family Law Act 1975 (Cth), a de facto relationship as defined in s 4AA of the Family Law Act 1975 (Cth) has never existed between the applicant and the respondent;
THE COURT FURTHER ORDERS THAT:
2.If either party contends that the Court should make any further orders other than an order dismissing the application filed on 5 February, 2021 and the response filed on 15 April, 2021 then that party must, no later than 4.00pm on 21 September, 2022 file and serve:
(a)a minute of the order or orders sought; and
(b)written submissions of no greater than 5 pages in length in support of any proposed orders.
3.In the absence of either party filing and serving material pursuant to order 2 hereof, the Court shall on 22 September, 2022 order that the application filed on 5 February, 2021 and the response filed on 15 April, 2021 be dismissed.
Note: The form of the order is subject to the entry in the Court’s records.
Note: This copy of the Court’s Reasons for judgment may be subject to review to remedy minor typographical or grammatical errors (r 10.14(b) Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 10.13 Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth).
Section 121 of the Family…
Continue reading Swinbank & Stein
Sign in free to access the full text
- AGLC
- Swinbank & Stein [2022] FedCFamC1F 682
- Case
- [2022] FedCFamC1F 682
- Decision Date
CaseChat Overview and Summary
The court examined the evidence presented, including the parties' testimonies and the observations of their interactions. The court found the applicant's account of their relationship to be disingenuous and lacking in clarity, particularly regarding the nature of their cohabitation. The respondent's evidence suggested that, while they had a physical and parental relationship, the parties never truly lived together on a genuine domestic basis. The court concluded that, despite the applicants' claims and the presence of children, the relationship did not meet the legal definition of a de facto relationship as it did not involve the parties living together on a genuine domestic basis.
Ultimately, the court dismissed the applicant's application for property adjustment, determining that no de facto relationship existed between the parties. The court found that the applicant and respondent's relationship, while evolving over time, did not satisfy the criteria for a genuine domestic partnership as defined by the Act. Consequently, the court directed the parties to address any necessary consequential orders before making final dispositions of the proceedings.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Moreover, whilst the perception of the parties about the nature of their relationship is a relevant matter, it is not determinative: Sinclair & Whittaker (2013) FLC ¶93–551 at [65]. That is especially so when the parties or one of them, such as the applicant here, merely swears to the issue. The phrase de facto relationship will mean different things to different people and that meaning may change depending upon the context in which the phrase is being used. Unless the basis for a party’s opinion about the nature of the relationship is explained by reference to the facts, acts and other circumstances of the actual relationship between the parties concerned, the opinion will generally be of no probative value. What might be found to be a de facto relationship between two particular people might lack many of the indicia that many other de facto relationships exhibit: cf. Onslow & Onslow at [97]-[104].Consideration The parties commenced a relationship with each other in 2014. Over time, the nature of that relationship has changed. At first, it was a relationship whereby the parties would see each other occasionally and engage in sexual relations. They soon became parents and their relationship changed. They remain parents of two children and so, in that respect at least, they remain in a relationship. I am satisfied that their intimate relationship ceased in January, 2019. Their personal relationship became more difficult and fractious in the circumstances I have set out above in June, 2020. It has broken down since and contact between the applicant and the respondent has become almost non-existent. That is notwithstanding they remain the parents of two children. The submissions of the parties each drew a narrow bright line at the point at which each party contended their relationship ended. I do not consider, however, that the facts permit the drawing of any bright line about that issue. As I have indicated above, over time the parties’ relationship changed, but it nonetheless continues. That the parties went out to dinner on one evening in mid-2019 is not inconsistent with the proposition that the relationship changed over time or that it waxed and waned. The real question is whether at any point over the period from early 2014 until either early 2019 mid-2020 or some other time, the parties had a relationship as a couple living together on a genuine domestic basis. For the Court to conclude that parties had a relationship as a couple living together on a genuine domestic basis it is not necessary for the Court to find that the parties shared a common residence: Fairbairn v Radecki at [28], [33], [35] and [39]. I am not satisfied that the parties did share a common residence between early 2014 until mid- 2020 as the applicant contends. I am satisfied that whilst he would from time to time stay at the respondent’s home in B Street, K Town when it suited him, it was not his residence. Questions of the difference between a postal address and a residential address to one side, his representations to banks and others, including the Department of Transport, the Australian Taxation Office and his employers are, on the balance of probabilities, a more accurate and reliable indication of his place of residence than his assertions in these proceedings. That he may have had some deliveries made to the respondent’s address indicates that he may have been present at times, as I am satisfied he was, but I am not satisfied that it demonstrates that it was his place of residence.