Wolkowicz and Wolkowicz (No. 2)

In the matter of *Wolkowicz and Wolkowicz (No. 2)*, the Honourable Justice Cronin of the Family Court of Australia considered an application by the husband. The dispute concerned the wife's alleged failure to comply with court orders, leading to the husband's application for her arrest.

The central legal issue before the Court was whether to issue a warrant for the wife's arrest. This required the Court to determine if there were sufficient grounds to justify such a drastic measure, considering the wife's alleged non-compliance with previous orders and the need to ensure her attendance before the Court.

Justice Cronin reasoned that the wife's continued absence and failure to attend court proceedings, despite prior orders, necessitated the issuance of an arrest warrant. The Court explicitly authorised the Australian Federal Police and the Victorian Police Force to use necessary and reasonable force to execute the warrant, pursuant to section 122A of the *Family Law Act 1975* (Cth). The Court ordered that the wife be held in custody upon arrest until the determination of the husband's application, and that she be brought before the Court on a specified date.