Panayiotou v Registrar Edwards [2026] FCA 421

The applicant, Mr Panos Panayioutou, commenced this proceeding by an originating application for judicial review of a decision made by Registrar Edwards on 4 December 2025 to refuse to accept documents for filing under r 2.26 of the Federal Court Rules 2011 (Cth).
The applicant is self-represented. In support of the originating application, the applicant filed an affidavit, which he affirmed on 10 December 2025. The applicant also filed written submissions dated 4 February 2026 and 18 February 2026, without direction.
On 24 December 2025, the Registrar filed a notice submitting to any order that the Court makes in the proceeding, save as to costs.
On or around 18 February 2026, this matter was referred to a Registrar of the Court for the purposes of case management and the making of timetabling orders.
On 23 February 2026, Registrar Goucke listed the matter for case management hearing on 4 March 2026.
The applicant's address for service in the originating application was listed as Yongah Hill Detention Centre, and the telephone number provided was that of Yongah Hill. However, it became apparent that the applicant was no longer in immigration detention, and was in fact located in Adelaide. As such, the matter was listed for case management hearing via audio-visual link with a copy of the orders emailed directly to the applicant.
On 23 February 2026, the applicant responded by way of email, requesting dial in details. The Court provided the applicant with the relevant dial in details.
At the first case management hearing before Registrar Goucke on 4 March 2026, the applicant did not appear via audio-visual link nor via the dial in mechanism provided by the Court. Registrar Goucke made orders noting the applicant's nonattendance and adjourned the matter for a case management hearing on 10 March 2026.
A copy of the orders was sent to the applicant along with a teams link and dial in details for the next case management hearing. The applicant was asked to explain why he did not attend. He was warned that if he did not attend orders may be made in his absence or his case may be dismissed.
The applicant replied later that day. In his email, Mr Panayioutou did not provide an explanation for nonattendance and instead noted that "this should not stop the registrar from making processing arrangements for this matter."
The applicant did not attend the case management hearing on 10 March 2026. Registrar Goucke noted the applicant's nonattendance and listed the matter for final hearing for a date after 24 March 2026. The orders also raised for consideration whether the proceeding should be dismissed pursuant to s 37P of the Federal Court of Australia Act (Cth), having regard to the applicant's failure to appear at the case management hearings listed on 4 March 2026 and 10 March 2026, for hearing (the order provided that that issue was referred to a Judge of the Court for consideration at the hearing). The applicant was further directed to file an outline of submissions in support of the originating application by 30 January 2026.
On 13 March 2026, I directed my Associate to list the matter for hearing before me at 2.00pm (AEDT) on 27 March 2026 by audio-visual link. The applicant was notified by email at the email address given by him for service. The applicant was also sent details of the audio-visual link to appear at the hearing.
On 26 March 2026, the Court noted that the applicant had not filed an outline of submissions by 24 March 2026 pursuant to Order 1 of Orders dated 10 March 2026. The Court sent an email that day, directing the applicant to confirm if he seeks to rely on the submissions he previously filed without direction on 2 February 2026 and 18 February 2026, or whether he intended to file further submissions. The applicant did not provide a response.
The hearing was scheduled to commence at 2.00pm on 27 March 2026. The applicant called the Registry at 12.28pm regarding the hearing and asked for dial in details. He confirmed the hearing time in the conversation with Registry staff.
The applicant did not join the audio-visual link before 2.00pm. The applicant was called at 2.25pm as he had not connected and he said he thought the hearing time was 1.30pm. The applicant was directed to join the hearing by either the dial in details or the audio-visual link. The applicant had not done so by 2.30pm.
The hearing then commenced shortly after 2.30 pm. The matter was called and the applicant did not appear in person, via the dial in details or the audio-visual mechanism that was provided. I noted the applicant's nonattendance and adjourned the matter for final hearing to 10 April 2026. The applicant communicated with the Registry that he joined via dial in details at 2.35pm, after the hearing had been adjourned. I note that this was approximately 35 minutes after the matter had been listed for hearing.
On 27 March 2026, the applicant was notified that the matter had been adjourned for hearing on 10 April 2026 at 2.00pm. The applicant was provided with the relevant audio-visual link and dial in details, and notified that failure to attend the hearing may result in an order dismissing the proceeding. The applicant was also reminded that he had not filed submissions pursuant to Order 1 of Orders dated 10 March 2026 and was asked to confirm if he intends to file any written submissions. The Court sent an email in similar terms to the applicant again on 9 April 2026.
The applicant did not provide a response.
As I have said, the hearing was scheduled to commence at 2.00pm on 10 April 2026. The applicant did not join the audio-visual link or dial in link before 2.00pm. Shortly before the hearing was due to commence, the Registry contacted the applicant, and he indicated that he did not propose to attend. The hearing commenced shortly after 2.00pm. The matter was called on and the applicant failed to appear.
In the circumstances, I am satisfied of the following.
First, the applicant has had adequate notice of the hearing today.
Second, the applicant has failed to attend two case management hearings before Registrar Goucke and has not filed any written submissions pursuant to Order 1 of Orders dated 10 March 2026.
Third, the applicant has (twice) failed to attend the scheduled final hearing of his matter (the initial hearing on 27 March 2026 and today).
The fact that the applicant has not appeared today also means that no party has appeared today when the proceeding was called on for trial. That enlivens the court's powers under r 30.22 of the Rules. That rule provides:

Panayiotou v Registrar Edwards [2026] FCA 421 | Case summary | Zoe

The applicant, Mr Panos Panayioutou, commenced this proceeding by an originating application for judicial review of a decision made by Registrar Edwards on 4 December 2025 to refuse to accept documents for filing under r 2.26 of the Federal Court Rules 2011 (Cth).
The applicant is self-represented. In support of the originating application, the applicant filed an affidavit, which he affirmed on 10 December 2025. The applicant also filed written submissions dated 4 February 2026 and 18 February 2026, without direction.
On 24 December 2025, the Registrar filed a notice submitting to any order that the Court makes in the proceeding, save as to costs.
On or around 18 February 2026, this matter was referred to a Registrar of the Court for the purposes of case management and the making of timetabling orders.
On 23 February 2026, Registrar Goucke listed the matter for case management hearing on 4 March 2026.
The applicant's address for service in the originating application was listed as Yongah Hill Detention Centre, and the telephone number provided was that of Yongah Hill. However, it became apparent that the applicant was no longer in immigration detention, and was in fact located in Adelaide. As such, the matter was listed for case management hearing via audio-visual link with a copy of the orders emailed directly to the applicant.
On 23 February 2026, the applicant responded by way of email, requesting dial in details. The Court provided the applicant with the relevant dial in details.
At the first case management hearing before Registrar Goucke on 4 March 2026, the applicant did not appear via audio-visual link nor via the dial in mechanism provided by the Court. Registrar Goucke made orders noting the applicant's nonattendance and adjourned the matter for a case management hearing on 10 March 2026.
A copy of the orders was sent to the applicant along with a teams link and dial in details for the next case management hearing. The applicant was asked to explain why he did not attend. He was warned that if he did not attend orders may be made in his absence or his case may be dismissed.
The applicant replied later that day. In his email, Mr Panayioutou did not provide an explanation for nonattendance and instead noted that "this should not stop the registrar from making processing arrangements for this matter."
The applicant did not attend the case management hearing on 10 March 2026. Registrar Goucke noted the applicant's nonattendance and listed the matter for final hearing for a date after 24 March 2026. The orders also raised for consideration whether the proceeding should be dismissed pursuant to s 37P of the Federal Court of Australia Act (Cth), having regard to the applicant's failure to appear at the case management hearings listed on 4 March 2026 and 10 March 2026, for hearing (the order provided that that issue was referred to a Judge of the Court for consideration at the hearing). The applicant was further directed to file an outline of submissions in support of the originating application by 30 January 2026.
On 13 March 2026, I directed my Associate to list the matter for hearing before me at 2.00pm (AEDT) on 27 March 2026 by audio-visual link. The applicant was notified by email at the email address given by him for service. The applicant was also sent details of the audio-visual link to appear at the hearing.
On 26 March 2026, the Court noted that the applicant had not filed an outline of submissions by 24 March 2026 pursuant to Order 1 of Orders dated 10 March 2026. The Court sent an email that day, directing the applicant to confirm if he seeks to rely on the submissions he previously filed without direction on 2 February 2026 and 18 February 2026, or whether he intended to file further submissions. The applicant did not provide a response.
The hearing was scheduled to commence at 2.00pm on 27 March 2026. The applicant called the Registry at 12.28pm regarding the hearing and asked for dial in details. He confirmed the hearing time in the conversation with Registry staff.
The applicant did not join the audio-visual link before 2.00pm. The applicant was called at 2.25pm as he had not connected and he said he thought the hearing time was 1.30pm. The applicant was directed to join the hearing by either the dial in details or the audio-visual link. The applicant had not done so by 2.30pm.
The hearing then commenced shortly after 2.30 pm. The matter was called and the applicant did not appear in person, via the dial in details or the audio-visual mechanism that was provided. I noted the applicant's nonattendance and adjourned the matter for final hearing to 10 April 2026. The applicant communicated with the Registry that he joined via dial in details at 2.35pm, after the hearing had been adjourned. I note that this was approximately 35 minutes after the matter had been listed for hearing.
On 27 March 2026, the applicant was notified that the matter had been adjourned for hearing on 10 April 2026 at 2.00pm. The applicant was provided with the relevant audio-visual link and dial in details, and notified that failure to attend the hearing may result in an order dismissing the proceeding. The applicant was also reminded that he had not filed submissions pursuant to Order 1 of Orders dated 10 March 2026 and was asked to confirm if he intends to file any written submissions. The Court sent an email in similar terms to the applicant again on 9 April 2026.
The applicant did not provide a response.
As I have said, the hearing was scheduled to commence at 2.00pm on 10 April 2026. The applicant did not join the audio-visual link or dial in link before 2.00pm. Shortly before the hearing was due to commence, the Registry contacted the applicant, and he indicated that he did not propose to attend. The hearing commenced shortly after 2.00pm. The matter was called on and the applicant failed to appear.
In the circumstances, I am satisfied of the following.
First, the applicant has had adequate notice of the hearing today.
Second, the applicant has failed to attend two case management hearings before Registrar Goucke and has not filed any written submissions pursuant to Order 1 of Orders dated 10 March 2026.
Third, the applicant has (twice) failed to attend the scheduled final hearing of his matter (the initial hearing on 27 March 2026 and today).
The fact that the applicant has not appeared today also means that no party has appeared today when the proceeding was called on for trial. That enlivens the court's powers under r 30.22 of the Rules. That rule provides:

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