Australian Coal and Shale Employees' Federation v The Commonwealth

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).

Part XIVB of the Family Law Act 1975 (Cth) makes it an offence, except in very limited circumstances, to publish an account of proceedings that identify persons, associated persons, or witnesses involved in family law proceedings.

IT IS NOTED that publication of this judgment by this Court under a pseudonym Holinski & Holinski (No 3) has been approved pursuant to subsection 114Q(2) of the Family Law Act 1975 (Cth).

1. These reasons explain the dismissal of the mother's Application in a Proceeding filed on 11 August 2025 seeking an order for the stay of certain parenting orders made by me on 8 August 2025 pending the determination of her appeal.

1. The parties to these proceedings are the parents of two children, now aged thirteen (13) years and fifteen (15) years ("the children"). The children have been the subject of litigation in the Family Court of Australia (as the Court was then known) and Divisions One and Two of the Federal Circuit and Family Court of Australia since 2013. The family are the subject of nine published Judgments since 17 March 2014.
2. Following a contested hearing, which ran for a total of seven days, the Family Court of Australia made final parenting orders on 22 January 2016 ("the 2016 Orders"). Without examining the minutiae of the 2016 Orders, it is sufficient for a reader of this Judgment to understand that the 2016 Orders provided that:

(a) The children's parents have equal shared parental responsibility for them;

(b) The children live with the mother;

(c) During school term time, the children spend time with the father from the conclusion of school on Thursday to the commencement of school on Monday in each alternate week;[1] and

(d) The children spend half of each school holiday period with each of their parents.

1. The parties each complied with the 2016 Orders until November 2022. At that time, the mother asserts that there was a breakdown in the relationship between the children and their father. The father denied that any conduct by him caused the children to resist spending time with him.[2] Further, the father says that the mother decided to withhold the children from him as a consequence of his refusal to sign passport applications for the children so that they might travel with the mother to the United States of America.[3]
2. On 10 January 2023, the father filed an Application - Contravention. That application was compromised after the mother filed an Initiating Application seeking the suspension of the substantive provisions of the 2016 Orders.
3. A trial occurred between 10 and 12 June 2025. At the conclusion of the trial, I reserved my Judgment. On 8 August 2025, I delivered my decision and reasons for Judgment.[4]
4. Among other things, the final parenting orders made by me include orders that:

(a) From the date of the delivery of my Judgment until the commencement of the Christmas school holiday period in 2025, the father have sole decision-making authority for major long-term issues in relation to the children's health;

(b) On the delivery of the children to the father on 8 August 2025, the children not spend any time with the mother until the commencement of the Christmas school holiday period in 2025 ("the moratorium period");

(c) On completion of the moratorium period, the children spend time with each of their parents for one half of the 2025/2026 Christmas school holiday period;

(d) On the commencement of the academic year in 2026, the children live with each of their parents as follows:

(i) With the father from the conclusion of school on Wednesday (or 3.00pm if school is not in session) to the commencement of school on Monday (or the commencement of school on Tuesday if school is not in session on the Monday) in each alternate week; and

(ii) With the mother at all other times.

1. The mother appealed those Orders on 11 August 2025 ("the appeal"). Contemporaneously with the filing of the appeal, the mother filed an Application in a Proceeding seeking a stay of my Orders. At the hearing of the mother's stay application, the mother's counsel also advised me that the mother would consent to an order restoring orders made by a Senior Judicial Registrar on 8 June 2023. Those Orders provided for the children to live with the mother and spend time with the father for a period of three hours on each alternate Saturday with such time to be supervised by a professional supervision agency.[5]
2. By his Response to an Application in a Proceeding filed on 14 August 2025, the father invites me to dismiss the mother's application.

Events subsequent to the delivery of my judgment

1. The mother's affidavit filed in support of her application and the subsequent material filed by the father alerted me to the following:

(a) New South Wales police assisted the father to recover the children from the mother on 9 August 2025;[6]

(b) Having made efforts to recover the children, New South Wales police and the New South Wales ambulance service facilitated the children's transfer to the Y Hospital;[7] and

(c) On 13 August 2025, the children were discharged into the care of the father.[8]

1. During the children's admission to the Y Hospital, the children were the subject of assessments by workers at the Department of Communities and Justice. This being so, and on 12 August 2025, I invited the Minister for Communities and Justice to intervene in the proceedings. Although the Minister did not participate in the hearing of the application before me on 15 August 2025, the Minister, through the auspices of the Z Family Services, did produce a comprehensive letter to the Court in relation to the children's welfare. I released that letter to the parties on 15 August 2025. By the concluding sentences of the letter, the Minister advised that the Department required a period of 42 days to respond to the s 91B order made by me on 12 August 2025 at which time the Minister will decide whether to intervene in the proceedings.

(a) An Application in a Proceeding filed on 11 August 2025; and

(b) An affidavit in the name of the mother filed on 11 August 2025.

(a) A Response to an Application in a Proceeding filed on 14 August 2025.

(b) An affidavit in the name of the father filed on 14 August 2025.

1. On 12 August 2025, I requested the Independent Children's Lawyer to issue subpoenas to the Y Hospital, the New South Wales Department of Communities and Justice, the New South Wales Police Force and/or New South Wales Ambulance for the purposes of obtaining any records relating to the children. As a consequence of information revealed by that material and information provided by the father to the Independent Children's Lawyer pursuant to orders made by me on 12 August 2025, I heard evidence from the following at the hearing on 15 August 2025:

(a) Dr AA, senior clinical psychologist and psychologist at the Child and Adolescent Development Unit at Y Hospital; and

(b) Dr CC, head of the paediatrics department at Y Hospital.

1. The Independent Children's Lawyer invited me to mark the following documents as exhibits:

(a) A letter from the Z Family Services to the Court dated 14 August 2025 (supra)[9]; and

(b) Materials returned pursuant to subpoena by Y Hospital in relation to each child.[10]

1. Rule 13.12 of the Federal Circuit and Family Court of Australia (Family Law) Rules 2021 (Cth) ("the Rules") provides parties with the opportunity to apply for a stay of an order of the Court pending the outcome of an appeal.
2. As the judge who made the order under appeal, I have jurisdiction to hear and determine the application for a stay of the final orders. The principles relating to applications for a stay of orders are those described by Austin J in Zyma & Begum [2025] FedCFamC1A 11 at [15] to [16], as follows:
   1. The discretion to stay the operation of appealed orders should only be exercised where circumstances exist to justify departure from the ordinary rule that a successful litigant is entitled to the fruits of the litigation pending the determination of any appeal. Such circumstances justifying a stay will exist where it is necessary to prevent the appeal from being rendered nugatory or for whatever other reason there is a real risk it will not be possible for a successful appellant to be restored substantially to his or her former position if the judgment against him or her is executed (Federal Commissioner of Taxation v Myer Emporium Ltd (No 1) [1986] HCA 13; (1986) 160 CLR 220 at 222-223). The Court should also consider the prospects of the appeal and where the balance of convenience lies (see Jennings Constructions Ltd v Burgundy Royale Investments Pty Ltd (No 1) [1986] HCA 84; (1986) 161 CLR 681 at 685).
   2. Those common law principles apply equally to judgments delivered in this jurisdiction, including judgments in parenting proceedings (JRN & IEG [1998] HCATrans 263; (1998) 72 ALJR 1329; Sheldon & Weir (Stay Application) [2011] FamCAFC 5 at [14]-[15]; Aldridge v Keaton (Stay Appeal) [2009] FamCAFC 106 at [18]; Trahn & Long (No 2) [2008] FamCAFC 194 at [38]). In relation to the proposed stay of appealed parenting orders, the welfare of the child is now considered a significant, but not the paramount, consideration. Residential changes should desirably be limited as far as reasonably possible. The Court should also consider whether the child's present circumstances are satisfactory, the bona fides of the appeal, the apparent strength of the appeal, and the likely delay before the appeal is heard and determined.
3. The Full Court in Aldridge & Keaton (Stay Appeal) [2009] FamCAFC 106 ("Aldridge & Keaton (Stay Appeal)") confirmed the discretionary nature of the determination of an application for a stay pending appeal and identified eleven principles applicable to a stay application.[11] Those principles were adopted and applied in another Full Court decision in Cantrell & North & Anor (2019) FLC 93-921; [2019] Fam CAFC 127 ("Cantrell').[12]
4. Recently, the principles applicable to an application for a stay were described by Austin J in Navickas & Fried [2024] FedCFamC1A 248 ("Navickas") as follows:
   1. The power of the appeal court to stay the orders the subject of the appeal is found in s 38(1)(b) of the FCFCA Act.
   2. The discretion to stay the operation of appealed orders should only be exercised where circumstances exist to justify departure from the ordinary rule that a successful litigant is entitled to the fruits of the litigation pending the determination of any appeal. Such circumstances justifying a stay will exist where it is necessary to prevent the appeal from being rendered nugatory or for whatever other reason there is a real risk it will not be possible for a successful appellant to be restored substantially to his or her former position if the judgment against him or her is executed (Federal Commissioner of Taxation v Myer Emporium Ltd (No 1) [1986] HCA 13; (1986) 160 CLR 220 at 222-223). The Court should also consider the prospects of the appeal and where the balance of convenience lies (see Jennings Constructions Ltd v Burgundy Royale Investments Pty Ltd (No 1) [1986] HCA 84; (1986) 161 CLR 681 at 685).
   3. Those common law principles apply equally to judgments delivered in this jurisdiction, including judgments in parenting proceedings (JRN & IEG [1998] HCATrans 263; (1998) 72 ALJR 1329; Sheldon & Weir (Stay Application) [2011] FamCAFC 5 at [14]-[15]; Aldridge v Keaton (Stay Appeal) [2009] FamCAFC 106 at [18]; at ). In relation to the proposed stay of appealed parenting orders, the welfare of the children is now considered a significant, but not the paramount, consideration. Residential changes should desirably be limited as far as reasonably possible. The Court should also consider whether the children's present circumstances are satisfactory, the of the appeal, the apparent strength of the appeal, and the likely delay before the appeal is heard and determined.
5. The Navickas exposition of principles applicable to a stay application demonstrates that it is not necessary to separately address every one of the eleven principles set out in Aldridge & Keaton (supra).

1. I accept that the mother's appeal is bona fides. However, the father is equally entitled to presume that my discretionary judgment is correct.[13]
2. By her Notice of Appeal, the mother identifies four grounds of appeal. I set them out as follows:
   1. In it's [sic] consideration of Section 60CC(2), the Court erred by not placing significant weight upon the Single Expert's evidence that:

At fifteen years of age, and if the Court grants the father's application, the elder child is likely to "self-place back with the mother and his brother will follow". The expert opined that this "happens frequently"; (d) The children will "need heavy therapeutic help if there is to be a change of residence";

Having specifically taken that evidence into account at Paragraph 164 of his judgement [sic].

1. His Honor's [sic] conclusion at 167, "that counsel for the ICL and the Mother did not address the court with any evidence which might cause me to conclude that the Mother will comply with orders" was factually incorrect, as counsel for the Mother did make submissions as to the likelihood of the Mother complying with court orders including a submissions [sic] that she complied with Her Honor [sic] Justice Hannam's orders until 2016 until 2022 and again complied with the Court's orders from 2023 until the making of His Honor's [sic] orders.

2. His Honor [sic] placed insufficient weight on the totally [sic] of recommendations made by the single expert such that orders made did not properly address the risk that the children may:

3. Put themselves or others at risk by attempting to self-place back with the Mother;

4. Suffer psychological harm as a result of not having adequate therapeutic support to assist with a change in residence.

5. His Honor [sic] placed insufficient weight on the Children's views.

1. Whist I accept that the mother has "an arguable case", I note that the first, third and fourth grounds of appeal involve an assessment of matters of weight only.
2. In House v The King (1936) 55 CLR 409 at 504-505, the majority of the High Court said:

The manner in which an appeal against an exercise of discretion should be determined is governed by established principles. It is not enough that the judges composing the appellate court consider that, if they had been in the position of the primary judge, they would have taken a different course. It must appear that some error has been made in exercising the discretion. If the judge acts upon a wrong principle, if he allows extraneous or irrelevant matters to guide or affect him, if he mistakes the facts, if he does not take into account some material consideration, then his determination should be reviewed and the appellate court may exercise its own discretion in substitution for his if it has the materials for doing so.

(emphasis added)

1. On enquiry by me, the mother's counsel conceded that the first, third and fourth grounds of appeal are not grounded by any assertion that I had applied a wrong principle, taken into account extraneous or irrelevant matters, made a mistake of fact or failed to take into account some material consideration. Instead, the mother's counsel conceded that the grounds involved an assessment of matters of weight only and that this being so, the mother faced the difficulties referred to by the High Court in Gronow & Gronow [1979] HCA 63; (1979) 144 CLR 513. As was stated in that decision at [10]:

...an appellate court should be slow to overturn a primary judge's discretionary decision on grounds which only involve conflicting assessments of matters of weight.

1. Accordingly, and whilst I accept that the mother has "an arguable case", I consider that in the absence of those factors referred to above, an appellate court may be slow to overturn my discretionary decision on grounds which involve conflicting assessments of matters of weight only.
2. The second ground of appeal refers to my reasons at [167] wherein I said as follows:

...I consider that the risks presented by the mother's failure to support the children's relationship with their father is of such magnitude that I ought to give consideration to a change in the children's primary living arrangements. If I do not give consideration to such an outcome then I would be overlooking the harm identified by the single expert consequent to a severance of the children's relationship with their father. I make this comment in circumstances where by reason of her past conduct and the evidence, which the mother gave during the trial, I have no confidence that the mother will comply with any orders made by me or facilitate a relationship between the children and their father.

1. Again, and whilst I accept that the mother has "an arguable case", it is simplistic for the mother to assert that because she complied with the 2016 Orders until November 2022 I have fallen into error by expressing a lack of confidence in the mother's preparedness to comply with any orders made by me or facilitate a relationship between the children and their father. Those findings were also based on:

(a) The mother's decision in November 2022 to agree with the children that they would send her an emoji representing a swirl of brown faeces if they wished to be collected from their father's residence;[14]

(b) The secretive nature of messages sent by the mother to the children on 17 November 2022 and the mother's exhortation to the elder child to delete certain messages sent by her. The mother's behaviour demonstrated an intention to do whatever was necessary to undermine the children's relationship with their father;[15]

(c) The mother's failure to take the children to school on 16 December 2022 so that she might prevent the father from collecting the children. In turn, this behaviour meant that the children were deprived of an opportunity to spend time with their father pursuant to the 2016 Orders;[16]

(d) The mother's failure to persuade the children that their father does not present a risk to them;[17]

(e) The mother's encouragement of the children's views of their father so that she could reduce his involvement in the children's lives without impingement;[18]

(f) The mother's unnecessary attendance at the Suburb V Police Station in late 2023, which caused the elder child to be interviewed by police;[19]

(g) My finding that the mother was unable to shield the children from her negative views of the father;[20]

(h) The children's mapping "out [of] certain escape routes" with the knowledge and apparent consent of the mother in February 2023 to prepare for the possibility that they might be obliged to spend time with the father;[21] and

(i) The mother's failure to encourage the children to spend supervised time with their father on 24 June 2023 and 8 July 2023.[22]

1. For these reasons, I consider that there is a possibility that the mother's appeal will fail. Even if this conclusion is erroneous, I find that neither party will be personally prejudiced by the refusal of the stay application.
2. The mother's counsel asserts that the refusal of the stay application will be prejudicial to the children because it is not in their best interests to remain in the primary care of the father. I consider that submission to be an embodiment of the mother's belief. The mother's belief is not objective proof of the fact.
3. I acknowledge that the circumstances giving rise to the children's admission to Y Hospital as recorded by the notes of New South Wales Ambulance and the hospital itself are distressing. For example, the children apparently told ambulance officers that they would "rather die than live with dad" and one of the children threatened to "slit...[his] wrists".[23] The notes of ambulance officers also suggest that both children were "highly emotional" and made repeated threats of self-harm. This being so, a decision was made by ambulance officers to detain the children pursuant to the authority afforded to them by s 20 of the Mental Health Act 2007 (NSW). An officer employed by New South Wales Ambulance gave the following description in respect of the elder child's presentation in late 2025:

[Patient] stated suicidal ideation with self harm [sic], plan to cut wrists. Pt appeared with depressed mood, described hopelessness and distress, +++tearful. [Patient] attempted to hit NSWPF with metal pipe, attempted to abscond in NSWPF presence. Social and home stressors...[24]

1. The younger child's presentation was in similar terms.
2. On the day prior to their discharge from Y Hospital, Dr CC, attended on the children. His notes of that attendance record the following:

Attended children...after the morning multidisciplinary meeting between myself, NUM, Clin Psych, social worker and paed registrar.

Both boys were in bed together, calm, watching TV.

I introduced myself and asked an open-ended question ("How are things going for you?")

Without further prompting, both expressed feeling unsafe with father and stated in synchrony that would run away if placed in father's care.

Both children, provided general emotional statements when asked "what made them feel unsafe with their dad" without elaborating specific incidents. Both boys came with repetitive and strongly negative narratives about father and paternal family and fear about the contact with the father.

...

I noted strong alignment in views, repetitive rephrasing, and absence of positive recollections, which were consistent with psychologist's observation.

Interaction remained calm during my review; no behavioural escalation noted.[25]

1. Notwithstanding the dramatic circumstances in which the children were admitted to Y Hospital, the elder child was at the time of his discharge in mid-2025 "assessed to be clear from a mental health and medical perspective".[26] A similar assessment was made in relation to the younger child.
2. By reference to the notes of Y Hospital and the father's affidavit I learned that during the children's admission to hospital, the mother:

(a) Arranged for a friend to attend on the children in breach of injunctive orders made by me on 8 August 2025.[27] This act required the intervention of hospital staff; and

(b) Caused two mobile phones to be delivered to the children in breach of injunctive orders made by me on 8 August 2025.[28] The mother's counsel on my enquiry submitted that the mother was confused about the operation of my orders. In any event, the letter from the Z Family Services identifies that the children disclosed that they had been texting their mother during their stay at the hospital. I consider that the mother's failure to comply with my orders contributed to the children's distress.

1. As discussed above, I had the benefit of hearing directly from the two practitioners engaged with the children during their stay at Y Hospital, namely, Dr AA and Dr CC.
2. Dr AA gave oral evidence in the following terms:

(a) On first meeting the children, Dr AA says that both children were saying "I'm scared, where is [...], you can't make us go somewhere we feel unsafe". She advised me that:

(i) Both children wanted to tell their stories;

(ii) Each child was odd in his presentation. She described each child as "heightened" and "just wanted to simply get all this information out that was repetitive and well-rehearsed";

(iii) Any attempts to test the children's narrative or request for them to elaborate "would be ignored" and the children's narrative would "circulate back to the beginning";

(b) The children "have fragmentary memories of events" and lacked any ability to "elaborate or give a defined incident or event", which caused them to reject their father;

(c) The elder child, despite being fifteen years of age, was "remarkably immature for his age".[29] Indeed, Dr AA said that the child's immaturity was such that she had to "keep reminding" herself that he was in fact fifteen years of age;

(d) The children would refer to always refer to themselves as "we" never "I" and it was impossible to obtain any narrative from each child individually because "one would start and the other would finish the sentence";

(e) The children presented as "enmeshed" with the mother "sharing one view"; and

(f) In her opinion, the children presented as children who had been "deeply emotionally and psychologically abused". Dr AA also described the children's presentation as consistent with having been alienated from their father at a "severe level". She said that the children's alienation from their father is such that the children's "sense of reality and what is real" has been lost but that it is "easy to cut through their fears because they do not have the memories to back it up".

1. Dr CC's evidence was in similar terms. He gave oral evidence that the children were not assessed to have a mental health issue or any medical issue whatsoever. This being so, the children ought to have been discharged from the hospital prior to the date in mid-2025 save that they were refusing to leave the hospital together with their father.
2. The letter prepared by Z Family Services dated 14 August 2025 reveals the following:

(a) The children appeared "visibly fearful of their father but provided limited, scripted responses lacking detail". That information was provided to the Department by Dr AA and it was consistent with her oral evidence;

(b) Dr AA expressed an opinion that the children's presentation was caused by a "high level of parental alienation" and required "specialised therapeutic support" that was beyond the services, which could be afforded to the children by New South Wales Health;

(c) The children were aware that my Judgment was the subject of an appeal and asked when they would be returned to their mother; and

(d) The children "appeared very 'parrot like' in their responses with little information to collaborate [sic] the concerns", which they expressed in relation to their father.

1. The children were discharged into the care of their father with the agreement of the children and the Department on a date in mid-2025.[30]
2. On the children's discharge into the father's care, the Department assisted the father to make arrangements for the father and the children to stay with a family friend. The father advised me both orally and in his written evidence that:

(a) The children are safe, had settled into his care and were "slowly reconnecting and communicating" with him;[31]

(b) Steps had been taken by him to engage a parental alienation expert to begin therapy with the Children;[32]

(c) He had taken indefinite leave from his employment[33] so that he might care for the children; and

(d) He is working with the children's school principal and the Department of Education to facilitate their schooling.[34]

1. I am bound to cause finality to be afforded to the children who have been the subject of litigation, and the emotional trauma associated with such litigation for the best part of eleven years. I agree with the submission made by the Independent Children's Lawyer on 15 August 2025:

Recent developments indicate that the children have settled. In the event that the stay was to be granted, they would then be removed, placed back with the mother, and then at the appeal may again be returned to the father or stay with the mother, and I think that is a significant concern.

1. I recognise that changes in the children's primary living arrangements should be minimised. A stay of my Orders would be incompatible with that objective by requiring the children to now return to the mother's primary care. If the stay is granted, the children will be deprived of an opportunity to reconnect with their father. Further, if the mother's appeal ultimately fails, there will be another change of the children's living arrangements. If the stay is refused and the mother's appeal succeeds, only one change of residence back to the mother from the father will be required.
2. Further, I concluded that the children were at risk of harm in the mother's care. If I accede to the mother's application, I would be implementing an outcome, which is profoundly incongruent with my findings as to the unacceptable risk presented by the mother. It now seems that my findings are consistent with the observations of the clinical psychologist and the paediatrician who attended on the children at Y Hospital.
3. I am advised by the mother's counsel that the Full Court is hearing and determining appeals with expedition. I am also satisfied that the appeal will be heard with expedition.
4. For these reasons, I dismiss the mother's application for a stay of my final orders.

I certify that the preceding forty-six (46) numbered paragraphs are a true copy of the Reasons for Judgment of the Honourable Justice Anderson.

[1] Orders made 22 January 2016, paragraph 6(a)(i).

[2] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [17].

[3] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [21].

[4] Holinski & Holinski (No 2) [2025] FedCFamC1F 530.

[5] Orders made on 8 June 2023, paragraph 3.

[6] Father's affidavit filed 14 August 2025, paragraph 9.

[7] Father's affidavit filed 14 August 2025, paragraph 12.

[8] Father's affidavit flied 14 August 2025, paragraph 26.

[11] The eleven dot points have been described as 'the First XI' of stay principles.

[12] Cantrell & North & Anor (2019) FLC 93-921; [2019] Fam CAFC 127 at [33].

[13] Australian Coal and Shale Employees' Federation v The Commonwealth [1953] HCA 25; (1953) 94 CLR 621 at 627.

[14] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [96].

[15] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [101].

[16] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [107].

[17] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [120].

[18] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [121].

[19] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [122].

[20] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [135].

[21] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [136].

[22] Holinski & Holinski (No 2) [2025] FedCFamC1F 530 at [139] and [141].

[23] Exhibit ICL2 as that exhibit relates to the elder child.

[24] Exhibit ICL2 as that exhibit relates to the elder child at page 6 of 73.

[25] Exhibit ICL2 as that exhibit relates to the elder child at page 11 of 73.

[26] Exhibit ICL2 as that exhibit relates to the elder child at page 7 of 73.

[27] Orders made on 8 August 2025, paragraph 10.

[28] Father's affidavit filed 14 August 2025, paragraphs 18 and 20.

[29] Transcript dated 15 August 2025, page 8.

[30] Father's affidavit filed 14 August 2025, paragraph 28.

[31] Father's affidavit filed 14 August 2025, paragraph 39.

[32] Transcript dated 15 August 2025, page 30.

[33] Father's affidavit filed 14 August 2025, paragraph 36.

[34] Father's affidavit filed 14 August 2025, paragraph 33.