Family Law Education Network

Category: Case Summaries

Bello & Opeyemi [2025] FedCFamC1A 179

In Bello & Opeyemi [2025] FedCFamC1A 179, the Father sought to appeal final parenting Orders made in December 2021 in respect of a then five-year-old child.  The Orders provided for only supervised time between the child and the Father on four occasions each year.  Those earlier Orders included a notation that if the Father completed three set courses, then he would not be precluded from revisiting the Orders in the future.  That notation was, of course, not binding in any future proceedings and not indicative of success in respect of any future application to vary those Orders.

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Berglund & Ungureanu [2025] FedCFamC1F 666

What is the correct venue? For most disputes involving parenting arrangements or property proceedings the correct venue will be the FCFCoA in either Division 1 or 2 however, in some circumstances that may not be the case. In the decision of His Honour, Reithmuller J, in Berglund & Ungureanu [2025] FedCFamC1F 666, the correct venue was the Supreme Court of NSW (“Supreme Court”) and the proceedings were therefore transferred.

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Evelyn & Kozel [2025] FedCFamC1A 171

Limitation dates in property matters

Missing a limitation date can be fatal and such enquiries should be foremost in one’s mind when taking initial instructions. If the parties were married then whether or not they are divorced is important but the length of the separation not so much. However, if the parties were in a de facto relationship the date of separation is most important. If the client is close to, or even later than, the two-year separation period then it is

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Helmold & Mariya (No 2) [2025] FedCFamC1A 163

With the use of Artificial Intelligence (“AI”) on the rise it is imperative that if is used in proceedings it is so used with great caution. Although the case of Helmold & Mariya (No 2) [2025] FedCFamC1A 163 relates to the use of AI by a self-represented party, it is nonetheless a cautionary tale.

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Vaughan (No 2) [2025] FedCFamC1A 159

Harmful Proceedings Orders are being made more often it would seem and also in property proceedings, as opposed to parenting matters. In the case of Vaughan (No 2) [2025] FedCFamC1A 159 His Honour, Schonell J, determined an attempt by the applicant to cross-appeal from a decision in Vaughan & Vaughan (No 6) [2025] FedCFamC1F 531.

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Palmisano & Angelov [2025] FedCFamC1A 166

When entering into Consent Orders it is important to consider those Orders very carefully, especially any flow on effects. In Palmisano & Angelov [2025] FedCFamC1A 166, a decision of His Honour, Austin J, considered an appeal filed by the father in respect of Consent Orders made by a Division 2 Judge, on 20 August 2025.

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Sprule & Mollis [2025] FedCFamC2F 458

Parties in property proceedings often have difficulty in taking a commercial approach to those proceedings. Unfortunately, that failure can often result in a significant costs order. In the Division 2 decision of His Honour, Judge Shoebridge, Sprule & Mollis [2025] FedCFamC2F 458 the parties reached agreement

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Anderson v Child Support Registrar [2025] FCA 1022

The decision of Anderson v Child Support Registrar [2025] FCA 1022 was heard and determined in the Federal Court of Australia, it is relevant to the practise of family law as it relates to both Child Support and the Harman Obligation.

These proceedings involved an attempt by the applicant mother to obtain documents by way of discovery, in long running associated proceedings relating to child support. The specific Order was sought against the Child Support Registrar.

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Padgett [2025] FedCFamC1A 140

Padgett [2025] FedCFamC1A 140 involved proceedings in both the Magistrates Court of Western Australia and the Family Court of Western Australia where a ‘Harmful Proceedings’ Order had been made against the Applicant, Ms Padgett. Prior to May 2024 this was quite commonly referred to as the litigant having been declared a vexatious litigant and was generally the result of a litigant having filed multiple proceedings which were, quite often, doomed from the outset.

| Read More

Dunne v Lloyd [2025] WASCA 119

Appeals in Western Australia – 11/08/2025

The creation of the then Family Court by the passing of the Family Law Act, 1975, required each of the states to refer their governance of ‘matrimonial causes’ to the Federal Government. The Western Australia state government was not so keen on that idea and retained matrimonial causes within state jurisdiction. Accordingly, that Court operates as the Family Court of Western Australia (‘FCWA’) and with its own legislation the Family Court Act 1997 (FCA).

| Read More

Bello & Opeyemi [2025] FedCFamC1A 179

In Bello & Opeyemi [2025] FedCFamC1A 179, the Father sought to appeal final parenting Orders made in December 2021 in respect of a then five-year-old child.  The Orders provided for only supervised time between the child and the Father on four occasions each year.  Those earlier Orders included a notation that if the Father completed three set courses, then he would not be precluded from revisiting the Orders in the future.  That notation was, of course, not binding in any future proceedings and not indicative of success in respect of any future application to vary those Orders.

| Read More

Berglund & Ungureanu [2025] FedCFamC1F 666

What is the correct venue? For most disputes involving parenting arrangements or property proceedings the correct venue will be the FCFCoA in either Division 1 or 2 however, in some circumstances that may not be the case. In the decision of His Honour, Reithmuller J, in Berglund & Ungureanu [2025] FedCFamC1F 666, the correct venue was the Supreme Court of NSW (“Supreme Court”) and the proceedings were therefore transferred.

| Read More

Evelyn & Kozel [2025] FedCFamC1A 171

Limitation dates in property matters

Missing a limitation date can be fatal and such enquiries should be foremost in one’s mind when taking initial instructions. If the parties were married then whether or not they are divorced is important but the length of the separation not so much. However, if the parties were in a de facto relationship the date of separation is most important. If the client is close to, or even later than, the two-year separation period then it is

| Read More

Helmold & Mariya (No 2) [2025] FedCFamC1A 163

With the use of Artificial Intelligence (“AI”) on the rise it is imperative that if is used in proceedings it is so used with great caution. Although the case of Helmold & Mariya (No 2) [2025] FedCFamC1A 163 relates to the use of AI by a self-represented party, it is nonetheless a cautionary tale.

| Read More

Vaughan (No 2) [2025] FedCFamC1A 159

Harmful Proceedings Orders are being made more often it would seem and also in property proceedings, as opposed to parenting matters. In the case of Vaughan (No 2) [2025] FedCFamC1A 159 His Honour, Schonell J, determined an attempt by the applicant to cross-appeal from a decision in Vaughan & Vaughan (No 6) [2025] FedCFamC1F 531.

| Read More

Palmisano & Angelov [2025] FedCFamC1A 166

When entering into Consent Orders it is important to consider those Orders very carefully, especially any flow on effects. In Palmisano & Angelov [2025] FedCFamC1A 166, a decision of His Honour, Austin J, considered an appeal filed by the father in respect of Consent Orders made by a Division 2 Judge, on 20 August 2025.

| Read More

Sprule & Mollis [2025] FedCFamC2F 458

Parties in property proceedings often have difficulty in taking a commercial approach to those proceedings. Unfortunately, that failure can often result in a significant costs order. In the Division 2 decision of His Honour, Judge Shoebridge, Sprule & Mollis [2025] FedCFamC2F 458 the parties reached agreement

| Read More

Anderson v Child Support Registrar [2025] FCA 1022

The decision of Anderson v Child Support Registrar [2025] FCA 1022 was heard and determined in the Federal Court of Australia, it is relevant to the practise of family law as it relates to both Child Support and the Harman Obligation.

These proceedings involved an attempt by the applicant mother to obtain documents by way of discovery, in long running associated proceedings relating to child support. The specific Order was sought against the Child Support Registrar.

| Read More

Padgett [2025] FedCFamC1A 140

Padgett [2025] FedCFamC1A 140 involved proceedings in both the Magistrates Court of Western Australia and the Family Court of Western Australia where a ‘Harmful Proceedings’ Order had been made against the Applicant, Ms Padgett. Prior to May 2024 this was quite commonly referred to as the litigant having been declared a vexatious litigant and was generally the result of a litigant having filed multiple proceedings which were, quite often, doomed from the outset.

| Read More

Dunne v Lloyd [2025] WASCA 119

Appeals in Western Australia – 11/08/2025

The creation of the then Family Court by the passing of the Family Law Act, 1975, required each of the states to refer their governance of ‘matrimonial causes’ to the Federal Government. The Western Australia state government was not so keen on that idea and retained matrimonial causes within state jurisdiction. Accordingly, that Court operates as the Family Court of Western Australia (‘FCWA’) and with its own legislation the Family Court Act 1997 (FCA).

| Read More