Australian Salaried Medical Officers' Federation v Peninsula Health

(a) the deed of settlement between the applicants, the respondents, Gordon Legal and Hayden Stephens and Associates annexed as 'AG-1' to the affidavit of Mr Andrew Grech dated 7 March 2025 (the "Deed"); and

(b) the settlement scheme (the "Scheme"), in the form set out in Annexure A of the Deed.

1. Pursuant to s 33ZB of the Act, the persons affected and bound by the settlement of the proceedings are:

(a) the applicants;

(b) the respondents;

(c) Gordon Legal;

(d) Hayden Stephens and Associates; and

(e) the group members who did not file an opt out notice in accordance with s 33J of the Act and/or order 15 of the court's orders dated 1 April 2025, or who did file such a notice and have been reinstated as group members pursuant to order 7.

1. Pursuant to s 33ZF(1) of the Act, the applicants, the respondents and the group members each have leave to apply to the court for orders in respect of any issue arising in relation to the administration of the Scheme.

1. Pursuant to ss 33V(2) and 33ZF(1) of the Act, Gordon Legal and Hayden Stephens and Associates be jointly appointed as the Scheme Administrators to act in accordance with the Scheme and have the powers and immunities contemplated by the Scheme.

1. Pursuant to s 33ZF(1) of the Act, each of the five group members who:

(a) had opted out of the proceedings; and

(b) have since applied to be reinstated as group members, as set out at annexure AG-9 to the affidavit of Mr Grech affirmed on 21 August 2025,

be, in each case, reinstated as a group member in the proceeding from which they opted out.

1. The date by which group members were required to submit a registration form to the applicants' solicitors, pursuant to order 8 of the court's orders dated 1 April 2025, be extended nunc pro tunc to 23 September 2025.
2. Pursuant to ss 33V(2) and 33ZF(1) of the Act, the Scheme Administrators have the power to, in their reasonable discretion, accept a registration form submitted by a group member to the applicants' solicitors after 23 September 2025, and treat such a group member as a Registered Group Member, if they are reasonably satisfied that the group member did not submit the form before 23 September 2025 because of exceptional circumstances, having regard to the matters set out at clause 10.6 and 10.7 of the Deed.

1. Pursuant to ss 33V(2) and 33ZF(1) of the Act, within 14 days of the date of these orders, the State of Victoria pay the following sums of:

(a) $67,500,000.00 (in respect of 50% of the Settlement Sum);

(b) $20,802,849.68 (in respect the Legal Costs Sum);

(c) $17,500,000.00 (in respect of the Administration Costs Sum) (as those terms are defined in cls 5.1(a) - (c) of the Deed),

into the applicants' solicitors trust account (the "Account") as payments in accordance with cls 5.5 and 5.6 of the Deed.

1. Pursuant to ss 33V(2) and 33ZF(1) of the Act, by 15 July 2026, the State of Victoria pay the sum of $67,500,000.00 (being the remaining Settlement Sum) into the Account.

1. Pursuant to ss 33V(2) and 33ZF(1) of the Act, the costs of the applicants' solicitors payable under the Deed pursuant to cl 5.1(b) of the Deed in respect of the conduct of the proceeding on behalf of the applicants and group members, be approved in the amount of $20,802,849.68.
2. Pursuant to ss 33V(2) and 33ZF(1) of the Act, the costs of the Scheme Administrator in respect of the implementation and operation of the claims assessment and settlement scheme process under the Deed pursuant to cl 5.1(c) of the Deed be approved in the amount of $17,500,000.00.

Approval of amount to be deducted from Settlement Sum pursuant to the Deed

1. Pursuant to ss 33V(2) and 33ZF(1) of the Act, an amount of $430,000.00 be deducted from the Settlement Sum to reimburse the applicants for their time and out-of-pocket expenses in performing their role as representative of group members in the conduct of the proceeding, in the following sums:

(a) Dr Bolton: $75,000.00

(b) Dr Hodge: $40,000.00

(c) Dr McPadden: $35,000.00

(d) Dr Gaggin: $20,000.00

(e) Dr Peel: $20,000.00

(f) Dr Lisik: $20,000.00

(g) Dr Sarkar: $15,000.00

(h) Dr Hand: $15,000.00

(i) Dr Bian: $15,000.00

(j) ASMOF: $175,000.00

1. Pursuant to ss 22, 23 or 33ZF of the Act, and/or r 1.32 of the Federal Court Rules 2011 (Cth) and/or the court's implied jurisdiction and upon the date that the Scheme Administrators file a confidential report with the court in accordance with cl 5.10 of the Deed, the proceedings be dismissed (without the need for any further order).

1. There be no order as to costs in the proceedings.

1. Pursuant to s 37AF(1) of the Act and until the conclusion of the corresponding period identified in the table below - and on the ground that it is necessary to prevent prejudice to the proper administration of justice under s 37AG(1)(a) of the Act - there be no publication or other disclosure of the materials identified in the table below, save to the extent there identified:

From the beginning of the paragraph to the words "... between February..."

Between the words "... as potential representative applicants,..." and "... who were then..." in the final sentence

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

From the beginning of third sentence to the words "... a considerable amount of work..."

Until the expiry of any appeal period following approval of settlement

From the beginning of the first sentence to the words "... a claim that"

In the final sentence, from the words "... to introduce a similar allegation... " to the words "... noting that Hodge"

In the first sentence of the second paragraph, from the words "... until May 2023..." to the end of the sentence

Last sentence, from the words "... was performed because..." to the end of the sentence

Until the expiry of any appeal period following approval of settlement

The values following the words "... claims is between..." and "... excluding legal costs..."

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

The value following the words "... economic loss of..."

Until the expiry of any appeal period following approval of settlement

Whole paragraphs (including the table following 99)

The values between the words "... is from..." and the words "... (excluding legal costs)..."

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

Between the words "... at paragraph 97(a)..." and the word "apply"

Until the expiry of any appeal period following approval of settlement

From the word "apply" to the end of the paragraph

From the heading immediately preceding paragraph 104 to the words "junior doctors" in paragraph 106

The words between "junior doctors" and "... work on short, fixed term contracts"

Whole paragraphs (including the heading immediately before paragraph 127)

Until the expiry of any appeal period following approval of settlement

Assumptions used in applicants' Loss Assessment Model (AG-4)

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

The expert report of Ms Kerrie Rosati dated 19 August 2025 (AG-8)

The names, employers, addresses, email addresses and phone numbers of each reinstatement applicant (insofar as that information is present in each application)

The names, employers, addresses, email addresses and phone numbers of each group member who filed an objection notice (insofar as that information is present in each objection notice)

The names and positions of AMA and ASMOF employees in sub‑paragraphs (a), (b) and (c)

From the words "... I was contacted by Mr Stephens..." to the end of the paragraph

Until the expiry of any appeal period following approval of settlement

From the start of the paragraph to the words "... Mr Stephens thereafter..."

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of settlement

From the words "... scope of the investigation..." to the end of the second sentence

Between the words "... due to the need to..." to "... and explain why..." in the third sentence

From the words "... to obtain information, including:..." to the end of the paragraph

Until the expiry of any appeal period following approval of settlement

From the words "... regarding those doctors, particularly..." to the end of the first sentence

Until the expiry of any appeal period following approval of settlement

From the words "... from ASMOF by..." to the end of the first sentence

From the words "... on matters relating to..." to the end of the third sentence

Until the expiry of any appeal period following approval of settlement

From the words "... with senior doctors to..." to the end of the penultimate sentence

Until the expiry of any appeal period following approval of settlement

Until the expiry of any appeal period following approval of the settlement

From the start of the second sentence to the end of the paragraph

Until the expiry of any appeal period following approval of settlement

Between the words "... representing junior doctors,..." and "... ASMOF found itself..."

From words "... leading role in litigation doctors,..." to the end of the penultimate sentence

From the words "... the sum paid to ASMOF..." to the end of the first sentence

From the words "... group members because..." to the end of the second sentence.

Between the words "... was used to..." and "... meaning that the balance..." in the third sentence

Until the expiry of any appeal period following approval of settlement

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

The Australian Salaried Medical Officers' Federation & Anor v Peninsula Health

The Australian Salaried Medical Officers' Federation & Anor v Monash Health & Ors

The Australian Salaried Medical Officers' Federation & Anor v Western Health

The Australian Salaried Medical Officers' Federation & Anor v Eastern Health & Anor

The Australian Salaried Medical Officers' Federation & Anor v Alfred Health & St Vincent's Health

The Australian Salaried Medical Officers' Federation & Anor v Northern Health

The Australian Salaried Medical Officers' Federation & Anor v Bendigo Health

The Australian Salaried Medical Officers' Federation & Anor v Melbourne Health & Northeast Health Wangaratta

The Australian Salaried Medical Officers' Federation & Anor v Goulburn Valley Health & Anor

The Australian Salaried Medical Officers' Federation v Austin Health

The Australian Salaried Medical Officers' Federation v The Royal Children's Hospital

The Australian Salaried Medical Officers' Federation v Albury Wodonga Health

The Australian Salaried Medical Officers' Federation v Bass Coast Health

The Australian Salaried Medical Officers' Federation v Calvary Health Care Bethlehem Limited

The Australian Salaried Medical Officers' Federation v Central Gippsland Health Service

The Australian Salaried Medical Officers' Federation v East Grampians Health Service

The Australian Salaried Medical Officers' Federation v Echuca Regional Health

The Australian Salaried Medical Officers' Federation v the

Victorian Institute of Forensic Mental Health (trading as

Forensicare)

The Australian Salaried Medical Officers' Federation v Western District Health Service

The Australian Salaried Medical Officers' Federation v Gippsland Southern Health Service

The Australian Salaried Medical Officers' Federation v West Gippsland Healthcare Group

The Australian Salaried Medical Officers' Federation v Grampians Health

The Australian Salaried Medical Officers' Federation v the Royal Victorian Eye and Ear Hospital

The Australian Salaried Medical Officers' Federation v Mercy Hospitals Victoria Limited

The Australian Salaried Medical Officers' Federation v Swan Hill District Health

The Australian Salaried Medical Officers' Federation v Mildura Base Public Hospital

The Australian Salaried Medical Officers' Federation v NCN Health

The Australian Salaried Medical Officers' Federation v South West Healthcare

The Australian Salaried Medical Officers' Federation v Peter MacCallum Cancer Institute

The Australian Salaried Medical Officers' Federation v Portland District Health

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

EASTERN HEALTH and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

ALFRED HEALTH and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

ST VINCENT'S HOSPITAL (MELBOURNE) LIMITED (ACN 052 110 755)

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

MELBOURNE HEALTH and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION and another named in the schedule

GOULBURN HEALTH and another named in the schedule

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

THE VICTORIAN INSTITUTE OF FORENSIC MENTAL HEALTH (TRADING AS FORENSICARE)

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

AUSTRALIAN SALARIED MEDICAL OFFICERS' FEDERATION

1. Pursuant to s 33V of the Federal Court of Australia Act 1976 (Cth) (the "Act"), the settlement of this proceeding, as set out in the orders made today in VID 115 of 2021, be approved.
2. For the avoidance of doubt (if any), the settlement so approved is approved on the basis that it applies globally to the various proceedings (including this one) in respect of which it has been reached and not cumulatively as between this proceeding and others.

Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.

1. On 20 October 2025, I published my reasons in relation to a settlement approval sought in 30 representative proceedings concerning the alleged underpayment of junior doctors in Victorian public health services: Australian Salaried Medical Officers' Federation v Peninsula Health (No 4) [2025] FCA 1268 (Snaden J) ("Approval Reasons"). These reasons assume familiarity with the Approval Reasons and adopt the definitions therein.
2. By the Approval Reasons, I indicated that there was a need for limited deviation from the orders that the parties had requested. Accordingly, the orders that were made required that the parties confer and provide their views on alternative forms of orders. That has now occurred and the parties have proposed, by consent, a slightly amended form of order. Two of the amendments were typographical and plainly appropriate. The remaining (and only substantive) amendment proposed the insertion of an order that reads as follows:
   1. Pursuant to ss 33V(2) and 33ZF(1) of the [Federal Court of Australia Act 1976 (Cth)], the Scheme Administrators have the power to, in their reasonable discretion, accept a registration form submitted by a group member to the applicants' solicitors after 23 September 2025, and treat such a group member as a Registered Group Member, if they are reasonably satisfied that the group member did not submit the form before 23 September 2025 because of exceptional circumstances, having regard to the matters set out at clause 10.6 and 10.7 of the Deed.

1. Clauses 10.6 and 10.7 of the Deed convey a discretion on the Scheme Administrator to extend the time by which a "Group Member, Registered Group Member or Eligible Claimant is required by [the] Deed or Settlement Scheme to complete any step in the Claims Assessment process" if the Scheme Administrator is satisfied that the step was not completed "because of exceptional circumstances". That discretion must be exercised reasonably and a number of mandatory considerations govern its exercise. Those considerations relate to matters such as the timely distribution of settlement payments and the nature of the exceptional circumstances.
2. The parties explained in their covering email to the court:

The parties consider such an order to be appropriate having regard to paragraph 39 of the [Approval] Reasons, which states that "any group member who has failed to submit their registration by that time due to exceptional circumstances may apply to the Settlement Scheme's administrators for a further extension." The parties note that the Scheme Administrators have the power under cl 10.6 of the Deed to extend the time by which "any step in the Claims Assessment process" is to be completed, but respectfully do not consider that the Scheme Administrators are empowered by the Deed to extend the date by which group members may submit their registration, that being a step antecedent to the commencement of the Claims Assessment process. The parties consider that the order proposed at paragraph 9 of the attached would rectify this issue.

1. I am satisfied that such an order is appropriate and would give effect to the Approval Reasons, as well as the terms of the Settlement Scheme itself.
2. With those deviations explained (and endorsed), I adhere to the views expressed in the Approval Reasons and will make the orders proposed by consent.

I certify that the preceding six (6) numbered paragraphs are a true copy of the Reasons for Judgment of the Honourable Justice Snaden.