Hospitality Employer Underpaid Staff, Falsified Payslips, and Took Adverse Action: How the Court Determined a $100k+ Pecuniary Penalty?

Hospitality General Protections and Underpayment Penalty Setting: How should civil penalties be calibrated for deterrence when an employer defaults, a vulnerable worker is underpaid, and employment is terminated for a prohibited reason?

Based on the authentic Australian judicial case MLG 1595 of 2023; Federal Circuit and Family Court of Australia (Division 2); [2025] FedCFamC2G 1275, this article disassembles the Court’s judgment process regarding evidence and law. It transforms complex judicial reasoning into clear, understandable key point analyses, helping readers identify the core of the dispute, understand the judgment logic, make more rational litigation choices, and providing case resources for practical research to readers of all backgrounds. :contentReference[oaicite:0]{index=0}

Introduction

This matter concerns the Court’s task of setting final relief in the form of pecuniary penalties under the Fair Work Act 2009 (Cth) after liability had already been established by declarations, and the Respondent continued to elect not to participate. The case sits at the intersection of general protections, minimum wage and Award compliance, payslip integrity, and the protective purpose of civil penalties: deterrence in the public interest.

Chapter 1: Case Overview and Core Disputes

Basic Information

Court of Hearing: Federal Circuit and Family Court of Australia (Division 2)
Presiding Judge: Judge Mansini
Cause of Action: Industrial law; Fair Work; application for pecuniary penalties for contraventions including general protections and minimum entitlements, regular payment, and payslip obligations
Judgment Date: 11 August 2025
Core Keywords:
- Keyword 1: Authentic Judgment Case
- Keyword 2: Fair Work Act civil penalties
- Keyword 3: General protections adverse action
- Keyword 4: Hospitality industry vulnerability
- Keyword 5: Award underpayments and entitlements
- Keyword 6: Default judgment and relief in default

Background

The Applicant was employed by the Respondent in the hospitality sector for a short period. During that employment, the Applicant’s minimum workplace entitlements were not met across multiple compliance points: lawful pay, penalty rates, overtime, superannuation obligations, annual leave-related obligations, and payslip accuracy. The dispute then moved into a legal arena that was not merely about whether compliance failures occurred, but about what consequences should follow once those failures were declared and the Respondent chose to disengage from the Court process.

The proceeding reached a stage where the Court had already made declarations of contraventions and then needed to decide final relief. The Respondent did not participate in the penalty phase, despite notice and opportunity. This put the Court in a position where it had to assess penalties that were appropriate to deter future contraventions, protect vulnerable workers, and uphold the statutory scheme, all in the absence of responsive evidence from the Respondent about circumstances such as financial position or compliance steps.

Core Disputes and Claims

What the Court was required to determine:
How to fix an “appropriate” pecuniary penalty under s 546(1) of the Fair Work Act 2009 (Cth) for multiple declared contraventions, where liability was established and the Respondent did not engage in the relief stage, and where deterrence objectives were central.
Applicant’s claims / relief sought:
A pecuniary penalty order requiring the Respondent to pay a penalty at a modest proportion of the aggregate maximum, proposed at about 10 to 15 per cent of the maximum available for the declared contraventions, and payable to the Applicant.
Respondent’s position:
No appearance; no material filed; no submissions on relief; continued election not to participate.

Chapter 2: Origin of the Case

The litigation began in a familiar real-world pattern seen in hospitality disputes: a short engagement, a vulnerable worker with limited bargaining power, and a workplace relationship where pay practices and record-keeping did not reflect statutory standards.

The Applicant’s working arrangement rapidly became financially interwoven with day-to-day survival needs: wages, penalty rates, and overtime are not abstract items to a low-paid worker; they are the difference between stability and crisis. When payment is partial, delayed, or undocumented, the worker’s financial position can deteriorate quickly, and the worker’s capacity to challenge workplace practices is constrained by fear of job loss.

Within this relationship, conflict commonly emerges in stages:

Early signs of imbalance: uncertainty about rates of pay, missing or unreliable payslips, and unclear entitlements under the Restaurant Industry Award 2020 and the National Employment Standards.
Escalation trigger: the worker begins to ask questions, seek clarification, or exercise a workplace right, directly or with the assistance of a third party acting for the worker’s benefit.
Decisive moment: the employment relationship collapses, not simply as a breakdown of trust, but through an action that the Fair Work Act treats as legally significant: termination for a prohibited reason connected to workplace rights, characterised in general protections terms as adverse action.

From there, the dispute moves from workplace reality into litigation reality. The Applicant pursued enforcement through the statutory civil remedy framework. The Respondent’s disengagement from the Court process then became a procedural fact with substantive consequences: the Court still had to ensure the Act’s protective purposes were met.

Chapter 3: Key Evidence and Core Disputes

Applicant’s Main Evidence and Arguments

Because this reasons for judgment is focused on penalty relief following earlier declarations, the evidentiary focus is anchored in what had already been established in the earlier reasons and declarations, and in the materials relevant to penalty.

The Applicant’s case, at its core, relied on a modular body of proof typically found in wage and general protections matters:

Employment period and duties evidence: evidence of the short term of employment and the work performed.
Pay evidence: proof of what was paid versus what was required, including underpayment of minimum rates, penalty rates, overtime, and failure to pay wages in full.
Entitlement evidence: evidence supporting failures concerning annual leave payment on termination and failure to provide the Fair Work Information Statement.
Award compliance evidence: reliance on Award clauses on minimum pay, penalty rates, overtime, superannuation, and access to instruments.
Payscale integrity evidence: payslips that did not contain prescribed information, and payslips that were false or misleading.
General protections narrative evidence: material supporting that the termination was for a prohibited reason connected with the Applicant’s workplace rights or the exercise of workplace rights by a third party for the Applicant’s benefit.
Procedural evidence: evidence that the Respondent was on notice of the proceedings and of Court orders, but failed to participate.

On penalty, the Applicant advanced a calibrated deterrence submission: despite a large maximum aggregate, the Applicant sought a proportionate penalty at around 10 to 15 per cent of the aggregate maximum.

Respondent’s Main Evidence and Arguments

None. The Respondent filed no material for the relief stage and did not appear.

This absence is not neutral. It denies the Court access to potentially relevant matters for penalty discretion, including evidence of:
– compliance systems,
– attempts at remediation,
– financial constraints,
– cooperation, contrition, or cultural change.

Core Dispute Points

Penalty purpose: whether the penalty should be set primarily to deter and protect the public interest in compliance.
Penalty quantification: what proportion of the maximum is appropriate given multiple contraventions and vulnerability factors.
Course of conduct: whether the contraventions should be treated as arising from a single course of conduct for aggregate penalty assessment.
Non-participation impact: how the Respondent’s refusal to engage affects findings about deliberateness, contrition, and deterrence.

Chapter 4: Statements in Affidavits

Affidavits in Fair Work litigation perform two simultaneous functions: they prove facts, and they tell a story that makes legal consequences intelligible.

In a typical wage and general protections dispute, the Applicant’s affidavit structure tends to align with statutory elements:

Chronology: when employment began, what was promised, what work was performed, and when conflict arose.
Entitlements mapping: what rates were required, what hours were worked, and what payments were made.
Document handling: whether payslips were issued, and if so, whether they were accurate and compliant.
Workplace rights context: what complaints, queries, or steps were taken by the Applicant (or on the Applicant’s behalf), and the timing of termination relative to those steps.

By contrast, a Respondent affidavit, when present, often attempts to reframe either the hours, the classification, the agreed rate, or the causal narrative around termination. Here, the Respondent provided no affidavit material, which created a one-directional evidentiary record: the Applicant’s sworn narrative and supporting material stood unrebutted at the relief stage.

Strategic Intent Behind the Court’s Procedural Directions

The Court’s procedural directions requiring material on relief and then proceeding in default reflect a basic judicial function: the Court must be able to finalise proceedings fairly and efficiently when a party refuses to participate but has had notice and opportunity.

The strategic intent is not to punish non-participation as a moral failing, but to protect the integrity of the Court’s processes and the statutory enforcement regime. A civil remedy system collapses if respondents can evade deterrent consequences by simply ignoring orders.

Chapter 5: Court Orders

Before the final relief determination, the Court made procedural arrangements that included:

orders requiring the filing of material relevant to relief following declarations of contravention;
orders designed to ensure the Respondent had notice of the proceedings and the consequences of non-compliance;
ultimately, a procedural pathway allowing determination of relief in the Respondent’s default pursuant to the relevant rules.

The final orders included:

an order that the Respondent pay a pecuniary penalty to the Applicant in a specified total amount by a specified date pursuant to s 546(1) of the Fair Work Act 2009 (Cth);
an order requiring the Applicant to serve the penalty orders (and earlier reasons) on the Respondent by specified means, and to file evidence of such service.

Chapter 6: Hearing Scene: Ultimate Showdown of Evidence and Logic

Process Reconstruction: Live Restoration

The penalty determination proceeded in a posture that is procedurally stark but legally common: a default relief setting where the Respondent did not appear. In that setting, the “showdown” is not between two advocates testing witness accounts in real time. Instead, the confrontation is between:

the statutory purpose of civil penalties and the Court’s obligation to uphold it; and
the practical reality of an absent contravener, with limited evidence about financial position or compliance posture.

The Applicant’s submissions became the primary vehicle for assisting the Court to translate established contraventions into an “appropriate” penalty figure. The Court then interrogated the penalty principles: deterrence, proportionality, and case-specific factors.

Core Evidence Confrontation

The decisive materials at this stage were:

the earlier declarations of contravention (the foundation of liability);
evidence that the Respondent was on notice yet refused to engage;
the characterisation of the contraventions as deliberate and reflective of disregard;
vulnerability factors in hospitality employment;
absence of rectification, compensation (at the penalty hearing stage), cooperation, and contrition;
the “course of conduct” characterisation for aggregation.

Judicial Reasoning: How Facts Drove the Result

The Court anchored the penalty task in settled authority: civil penalties under the Fair Work Act are protective and deterrent, not compensatory in essence, and must strike a balance between severity and deterrence.

“An ‘appropriate’ penalty … strikes a reasonable balance between oppressive severity and the need for deterrence.”

This statement was determinative because it framed the Court’s central calibration task: not to maximise punishment, but to choose a penalty that is proportionate while still meaningful for compliance messaging, especially in an industry with known vulnerability risks.

The Court also applied the orthodox approach that penalty is an evaluative selection informed by multiple factors, not a mechanical tariff:

“Penalties are not a matter of precedent.”

That proposition mattered because the Applicant invited a proportionate percentage of the maximum. The Court accepted that the outcome had to be “idiosyncratic” to the Respondent’s conduct, non-participation, the short employment period, multiple contraventions, and the vulnerability context.

Finally, the Court treated deliberateness and disregard for workplace laws as aggravating features in the deterrence calculus, while acknowledging evidentiary limits on the Respondent’s financial circumstances.

Chapter 7: Final Judgment of the Court

The Court ordered that:

the Respondent pay a pecuniary penalty to the Applicant in the total amount of AUD $103,290.00, pursuant to s 546(1) of the Fair Work Act 2009 (Cth), in respect of the declared contraventions; and
the Applicant serve the orders and earlier reasons on the Respondent and file evidence of service.

The penalty amount represented 10 per cent of the aggregate maximum total penalty (aggregate maximum stated as AUD $1,032,900.00), consistent with the Court’s conclusion that a penalty at that level was proportionate while meeting general and specific deterrence objectives.

Chapter 8: In-depth Analysis of the Judgment: How Law and Evidence Lay the Foundation for Victory

Special Analysis

This case is procedurally significant because it demonstrates how the civil penalty regime remains operative even when a contravener attempts to defeat enforcement by disengaging. The Court’s reasoning shows that default does not deprive the Court of power; it shifts the evidentiary landscape. The Court uses what is available: established contraventions, vulnerability context, absence of contrition, and the need for deterrence.

It also illustrates a distinctive feature of Fair Work civil penalty practice: penalties can be ordered payable to an individual applicant in appropriate circumstances, reinforcing the protective, not merely institutional, dimension of the regime.

Judgment Points

Point 1: Civil penalties are protective and deterrent, not a private windfall mechanism
The Court held that the purpose of civil penalties is the promotion of the public interest in compliance and deterrence. This reframes the penalty hearing away from moral blame and toward regulatory effectiveness. The legal consequence is that the Court will prioritise a penalty that influences future behaviour in the industry and by the contravener, rather than mirroring compensatory loss.
Point 2: “Appropriate” requires proportionality, not maximalism
The Court determined that appropriateness is a balance: deterrence without oppressive severity. This matters to both applicants and respondents. For applicants, it means a well-crafted penalty submission should explain why a proposed figure is meaningful for deterrence. For respondents, it means even serious contraventions will not automatically attract the maximum, but they can still attract a substantial penalty where aggravating features exist.
Point 3: Multiple contraventions can be treated as a single course of conduct for penalty assessment
The Court accepted that the contraventions derived from a single course of conduct that was temporal and of the same factual basis. This is strategically important: it can influence aggregation and how the Court avoids double punishment while still reflecting the breadth of non-compliance. For practitioners, it highlights the need to articulate the factual unity or separateness of breaches.
Point 4: Vulnerability context in hospitality is a recognised aggravating consideration
The Court held that hospitality employees are generally at higher risk of denial of entitlements and treated the Applicant’s vulnerability features as relevant to penalty. This is jurisprudentially important because it embeds industry context into penalty calculus: deterrence must speak to the risk profile of the sector and the protective need.
Point 5: Non-participation undermines mitigation and strengthens the deterrence need
The Court found no cooperation and no contrition, and accepted that the Respondent was aware but declined to engage. The legal consequence is practical: silence removes mitigation pathways. A respondent who refuses to participate forfeits opportunities to establish financial constraints, remediation steps, compliance improvements, or regret that might otherwise influence penalty.
Point 6: Failure to rectify or comply with orders magnifies the regulatory message
The Court took into account that, at the time of the penalty hearing, the Respondent had not compensated the Applicant or rectified underpayments notwithstanding Court orders. This supports a stronger deterrence response because the contravener’s post-contravention conduct suggests continuing disregard.
Point 7: Evidence limits do not prevent meaningful penalties
The Court noted the absence of evidence on the Respondent’s financial resources. Rather than treating that gap as a barrier, the Court proceeded with an appropriate penalty based on the factors it could properly find. This underscores a critical enforcement principle: respondents cannot reliably avoid penalties by withholding evidence.
Point 8: Payment of penalties to an individual applicant can be appropriate
The Court determined it was appropriate in the circumstances for the penalty amount to be paid to the Applicant. This is a noteworthy practical point for litigants: penalty destination is not fixed, and submissions should address why payment to an individual advances the protective purposes of the Act in the case.

Legal Basis

The Court’s determination operated through these statutory anchors:

Fair Work Act 2009 (Cth) s 546(1): power to impose pecuniary penalties the Court considers appropriate for contravention of civil remedy provisions.
Civil remedy provisions established by declarations: ss 44, 45, 323, 340, 536(2), 536(3).
Relief framework: s 545(1) and the Court’s procedural ability to determine relief in default under the applicable Rules pathway.

In resolving evidentiary contradictions at the penalty stage, the Court relied on the weight of established findings (declared contraventions) and the absence of any contrary evidentiary material. The Court’s approach demonstrates that the “contradiction” in default cases is often not between two factual versions, but between what the law requires (compliance and deterrence) and what the contravener does (non-compliance and disengagement).

Evidence Chain

The logic “Conclusion = Evidence + Statutory Provisions” can be reconstructed as:

Declared contraventions exist
→ evidence and earlier reasons established contraventions of civil remedy provisions
→ statutory condition for s 546(1) satisfied.
Deterrence purpose is engaged
→ multiple contraventions + vulnerability context + lack of compliance culture indicators
→ public interest in compliance requires a meaningful penalty.
Aggravating factors outweigh mitigating factors
→ deliberate disregard + loss suffered + no rectification + no cooperation + no contrition
→ penalty should not be nominal.
Aggregation and proportionality
→ single course of conduct characterisation supports coherent total penalty
→ proportionate percentage of maximum is justified.
Order payable to Applicant
→ circumstances support directing payment to the individual affected.

Judicial Original Quotation

“The purpose of a civil penalty … is … deterrence of further contraventions.”

This was determinative because it framed the Court’s penalty decision as a protective tool to secure compliance, rather than a retrospective moral assessment.

“A penalty … totalling $103,290.00 is … appropriate in the circumstances.”

This was determinative because it recorded the Court’s final evaluative synthesis: the penalty figure selected was proportionate, deterrence-sufficient, and responsive to the specific factual matrix, including non-participation and vulnerability.

Analysis of the Losing Party’s Failure

The Respondent failed not merely on the merits already declared, but on the litigation strategy and compliance posture that followed:

Failure to engage: the Respondent’s continuing election not to participate removed any chance to contest penalty level or provide context that could support moderation.
Failure to comply with orders: non-compliance signalled continuing disregard, reinforcing specific deterrence necessity.
Failure to show contrition: absence of regret or compliance steps deprived the Court of mitigation indicators.
Failure to rectify: continued non-payment or non-rectification at the time of hearing elevated the need for a penalty that sends a message to the sector.

Reference to Comparable Authorities

Australian Building and Construction Commissioner v Pattinson (2022) 274 CLR 450
Ratio: civil penalties are protective and deterrent; an appropriate penalty balances deterrence against oppressive severity, and should be sufficient to incentivise compliance.
Commonwealth v Director, Fair Work Building Industry Inspectorate (2015) 258 CLR 482
Ratio: civil penalty regimes serve public interest objectives; deterrence is central, and penalties are not primarily compensatory.
Australian Ophthalmic Supplies Pty Ltd v McAlary-Smith [2008] FCAFC 8
Ratio: penalties are case-specific and not a matter of precedent; comparative penalty reasoning must not become a mechanistic tariff.

Implications

Workplace rights are not theoretical; they are legal safety rails. Exercising a workplace right, or seeking help to do so, tends to trigger statutory protection. The law treats retaliation as a serious compliance threat, not a private misunderstanding.
Records are power. Payslips and accurate wage records are often the hinge point between uncertainty and proof. When an employer’s records are false, misleading, or incomplete, the employer’s litigation position tends to deteriorate quickly.
Silence is expensive. Choosing not to participate in proceedings tends to remove the pathways that reduce risk: context, evidence, remediation, and persuasion. The Court will still act to protect statutory objectives.
Industry context matters. Courts do not assess penalties in a vacuum. Sectors with known vulnerability patterns attract a stronger deterrence focus because the public interest in compliance is heightened.
Deterrence is designed to protect the next worker, too. Penalties communicate standards across a market. Even where an individual worker is the applicant, the Court’s reasoning extends to the broader community benefit.

Q&A Session

If an employer does not show up, does the worker automatically win everything they ask for?
Not necessarily. The Court must still be satisfied about liability and must still fix “appropriate” relief. Default changes the evidentiary contest, but it does not convert the Court’s discretion into an automatic rubber stamp. The Court still applies statutory principles and proportionality.
Why would the Court award a penalty payable to the worker rather than to the Commonwealth?
The Fair Work civil remedy framework permits flexibility. In appropriate circumstances, payment to the applicant can reinforce protective purposes, including specific deterrence, and acknowledge that the enforcement burden has been carried by the affected worker.
Does a short employment period reduce penalties?
Duration is relevant but not determinative. A short period can still include multiple contraventions, deliberate conduct, and a serious general protections breach. The Court assesses the totality: nature, seriousness, vulnerability context, and deterrence needs.

Appendix: Reference for Comparable Case Judgments and Practical Guidelines

1. Practical Positioning of This Case

Case Subtype: Hospitality Employment Compliance and General Protections Adverse Action; civil penalties for underpayments, payslip contraventions, and prohibited termination conduct under the Fair Work Act 2009 (Cth)
Judgment Nature Definition: Final Judgment on relief in default (pecuniary penalties after declarations of contravention)

2. Self-examination of Core Statutory Elements

This case belongs to ③ Employment and Workplace Disputes (Industrial Relations Law). The following test standards are provided for reference only and must be applied carefully to the precise facts of any matter.

Core Test: Unfair Dismissal – Fair Work Act

Was there a valid reason for the dismissal related to capacity or conduct?
Evaluate the actual reason relied upon at the time of dismissal. If reasons shift over time, that inconsistency tends to weaken the employer’s position. Evidence can include termination communications, roster changes, messaging apps, and witness accounts of what was said contemporaneously.
Was the person notified of that reason?
A lawful process generally requires that the employee is told the reason in a way they can understand. Where language barriers exist, the adequacy of notification may require additional steps such as translation or a support person. A failure to notify tends to increase the risk that the dismissal is found harsh, unjust, or unreasonable.
Was the person given an opportunity to respond?
A genuine opportunity is more than a formality. It requires time, clarity, and a real capacity to answer allegations. Employers who make a decision first and invite a response later tend to face elevated risk.
Was the dismissal harsh, unjust, or unreasonable?
This is an evaluative conclusion based on the whole picture: the reason, the process, proportionality, the employee’s service, vulnerability factors, and the real-world impact of dismissal.

Core Test: General Protections

Was adverse action taken against the employee because they exercised a workplace right?
Identify the workplace right and the adverse action. The causal inquiry focuses on the operative reasons of the decision-maker. Evidence can include timing, statements made, emails, rosters, payroll changes, and the consistency of the employer’s explanation.
Practical note on proof dynamics:
General protections disputes often involve sharp credibility questions. Where documentary evidence is scarce, contemporaneous messages and consistent chronology become disproportionately important.

Core Test: Sham Contracting

Is the worker a genuine independent contractor or a disguised employee?
Examine control, delegation, tools and equipment, financial risk, integration into business, and whether the person works for multiple clients. Labels are less persuasive than substance. A misclassification tends to expand exposure: backpay, penalties, and superannuation consequences.

3. Equitable Remedies and Alternative Claims

In workplace disputes, statutory remedies may not capture every dimension of the wrong. Equity and common law doctrines can sometimes provide alternative pathways, although risks vary by facts and jurisdiction.

Procedural Fairness

Did the decision-maker afford Natural Justice?
Where a decision impacts rights and interests, fairness requires a hearing opportunity and absence of apprehended bias. In employment contexts, procedural fairness principles can surface through contractual, administrative, or disciplinary processes.

Ancillary Claims

If an unfair dismissal claim fails, can it be reframed as a general protections claim?
In some circumstances, yes. A dismissal might not meet an unfair dismissal jurisdictional threshold, yet still involve adverse action for a prohibited reason. The key is precise identification of the workplace right, careful chronology, and credible evidence of causation.

4. Access Thresholds and Exceptional Circumstances

Regular Thresholds

Unfair dismissal filing limit: typically 21 days from dismissal taking effect (subject to extension in limited circumstances).
Limitation periods and jurisdictional gateways: vary depending on forum and claim type; practitioners should map each claim to the correct statutory pathway early.

Exceptional Channels

Late filing extensions:
Extensions can be available where there are exceptional circumstances, such as serious illness, significant family crisis, or misleading conduct by the employer or a representative, though outcomes are fact-dependent and not assured.

Suggestion

Do not abandon a potential claim solely because a threshold appears unmet at first glance. Carefully identify whether an alternative statutory cause of action exists, whether an extension mechanism applies, and whether evidence supports exceptional circumstances. These issues tend to be determinative at the gateway stage.

5. Guidelines for Judicial and Legal Citation

Citation Angle

It is relatively suitable to cite this authority in submissions concerning:

calibration of civil penalties for Fair Work contraventions where deterrence is central;
penalty setting in hospitality and other vulnerability-exposed sectors;
consequences of non-participation and lack of contrition in civil penalty discretion;
treatment of multiple contraventions as a single course of conduct for penalty evaluation.

Citation Method

As positive support:
Where your matter involves multiple contraventions, vulnerability indicators, or demonstrated disregard for compliance, this case can support the proposition that meaningful penalties are required to serve general and specific deterrence, and that “appropriate” penalties balance deterrence against oppressive severity.
As a distinguishing reference:
If an opposing party relies on this case, you may distinguish it by showing genuine cooperation, early rectification, credible compliance improvements, proven financial constraints, or factual differences that reduce the deterrence need.

Anonymisation Rule

When discussing the case in client communications or public legal education, avoid using party names. Use Applicant and Respondent, and identify the matter by court, year, neutral citation, and file number.

Conclusion

This judgment demonstrates a core regulatory truth: the Fair Work civil penalty scheme remains effective even when a contravener refuses to participate. By applying deterrence-first principles, the Court fixed a proportionate but meaningful penalty that reinforces compliance expectations in a vulnerability-exposed industry.

Golden Sentence: Everyone needs to understand the law and see the world through the lens of law. The in-depth analysis of this authentic judgment is intended to help everyone gradually establish a new legal mindset: True self-protection stems from the early understanding and mastery of legal rules.

Disclaimer

This article is based on the study and analysis of the public judgment of the Federal Circuit and Family Court of Australia (MLG 1595 of 2023; [2025] FedCFamC2G 1275), aimed at promoting legal research and public understanding. The citation of relevant judgment content is limited to the scope of fair dealing for the purposes of legal research, comment, and information sharing.

The analysis, structural arrangement, and expression of views contained in this article are the original content of the author, and the copyright belongs to the author and this platform. This article does not constitute legal advice, nor should it be regarded as legal advice for any specific situation.

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