In a medical negligence claim, how are the legal consequences determined when respondents apply to amend their defence regarding the success of Kasai surgery and delayed diagnosis of Biliary Atresia?

Medical Negligence Defence Amendment Dispute: Is Leave to Amend Defences Permissible Despite Delay and Pre-Trial Prejudice?

Introduction
Based on the authentic Australian judicial case HANBY v STATE OF SA & ORS [2025] SASC 84, 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.

Chapter 1: Case Overview and Core Disputes

Basic Information:

Court of Hearing: Supreme Court of South Australia
Presiding Judge: The Honourable Justice McIntyre
Cause of Action: Civil: Application (Interlocutory Applications)
Judgment Date: 29 May 2025

Core Keywords:

Keyword 1: Authentic Judgment Case
Keyword 2: Medical Negligence
Keyword 3: Amendment of Defence
Keyword 4: Causation
Keyword 5: Interlocutory Application
Keyword 6: Procedural Fairness

Background:

This matter concerned interlocutory applications brought by the First, Second, and Third Respondents seeking leave to amend their respective defences in a complex medical negligence proceeding. The underlying claim by the Applicant alleged negligence related to the failure of the Kasai Portoenterostomy (Kasai) procedure and a delayed diagnosis of Biliary Atresia, leading to the need for an early liver transplant. The applications to amend were partly agreed upon by the Applicant, but specific proposed amendments remained contested. The trial itself was set down for two months, highlighting the significance of any pre-trial amendments.

Core Disputes and Claims:

The legal focus of the dispute in these interlocutory applications was whether the respondents should be granted leave to amend their defences at a late stage, prior to a substantial trial. The First and Second Respondents proposed amendments concerning the precise cause of the Kasai procedure’s alleged failure. The Second and Third Respondents sought amendments related to the question of delayed diagnosis of the Applicant’s Biliary Atresia. The Applicant’s claims were for damages arising from the alleged negligence. The respondents’ claims were for leave to amend their pleadings to reflect their evolving understanding of the case and the evidence.

Chapter 2: Origin of the Case

The litigation originated from allegations of medical negligence surrounding the diagnosis and treatment of the Applicant’s Biliary Atresia. The central event was a Kasai Portoenterostomy, a surgical procedure performed at the Women and Children’s Hospital on 23 September 2002. The Applicant contended that this procedure was unsuccessful due to a delay in its performance, which in turn necessitated an early liver transplant.

The core of the conflict emerged from the differing accounts of medical advice and actions taken in August 2002. The Second and Third Respondents, medical practitioners involved in the Applicant’s care, alleged that the Applicant’s mother failed to follow up on a referral to a paediatrician, Dr Tao. This failure, they contended, contributed to the delay in diagnosis. Conversely, the Applicant’s mother denied receiving any such referrals. This factual dispute over consultations and referrals in early August 2002 formed the crucial juncture where the legal relationship deteriorated, leading to the complex causation questions at the heart of the medical negligence claim. The outcome of the Kasai procedure and the subsequent progression of the Applicant’s condition, including recurrent cholangitis, further complicated the factual matrix and the determination of causation.

Chapter 3: Key Evidence and Core Disputes

Applicant’s Main Evidence and Arguments:

The Applicant presented a case based on the premise that the Kasai procedure was unsuccessful due to a delay in its performance, necessitating an early liver transplant. Evidence from medical expert conclaves, specifically a report dated 4 March 2025, formed a significant part of the Applicant’s case, particularly concerning issues of causation. The Applicant argued that the proposed amendments by the respondents were delayed without proper justification, unsupported by evidence (especially regarding Dr Ford’s role), and highly prejudicial, particularly as Dr Ford had not been disclosed as an expert witness in accordance with the Uniform Civil Rules (UCR) Part 14. For the “delay” amendments, the Applicant argued non-compliance with UCR 67.2, claiming a lack of fair notice regarding dates, steps, and particulars, making it difficult to respond.

Respondent’s Main Evidence and Arguments:

The First and Second Respondents’ original defences denied that any delay caused the Kasai procedure to be unsuccessful. Their proposed amendments shifted this stance to a denial that the Kasai was unsuccessful at all, initially, and affirmatively identified recurring acute cholangitis (bacterial infection) as the factor impeding its continuing success. The First Respondent supported this by referring to Dr Andrew Ford’s operation notes and a letter he wrote in November 2002, stating that Dr Ford, the surgeon, could provide factual evidence that the Kasai was initially successful. They also argued that the expert conclave answers did not preclude their amended pleading, suggesting experts may have assumed the Kasai’s failure.
The Second and Third Respondents argued that their proposed “delay” amendments were merely refinements of existing pleadings and did not introduce new material. They sought to plead that if the Applicant’s mother had acted on referrals/advice to see Dr Tao, Biliary Atresia would have been identified earlier, preventing causative delay.

Core Dispute Points:

Kasai Procedure Failure: Was the Kasai procedure initially successful and its subsequent failure caused by cholangitis, or was it unsuccessful from the outset due to delay? The key evidence here includes Dr Ford’s notes and testimony, and the expert conclave report.
Delayed Diagnosis: Did the Applicant’s mother’s alleged failure to follow referrals/advice contribute to the delayed diagnosis of Biliary Atresia, thereby impacting causation? The dispute centred on what advice was given during August 2002 consultations.
Procedural Fairness of Amendments: Are the proposed amendments by the respondents permissible given their timing, the explanations for delay, and the potential prejudice to the Applicant, particularly concerning the lack of particularity in the “delay” amendments as per UCR 67.2?
Role of Dr Ford: Should Dr Ford’s evidence be admitted, and if so, how broadly can he testify without straying into expert opinion or contradicting existing discovered documents?

Chapter 4: Statements in Affidavits

In this matter, various affidavits were filed by the parties to support their respective interlocutory applications. The First Respondent filed an affidavit outlining the rationale for its proposed amendments concerning the Kasai procedure, specifically addressing the recent location of Dr Andrew Ford, the surgeon who performed the procedure. This affidavit stated that Dr Ford had not been employed by the First Respondent since 2011 and no longer resided in Australia, but had recently been located by an investigator. The strategic intent behind this was to call Dr Ford as a factual witness to attest to the initial success of the Kasai procedure based on his operation notes and a letter from November 2002.

The Second and Third Respondents similarly relied on affidavits detailing their proposed “delay” amendments. These affidavits set out the parties’ positions regarding consultations in August 2002, including advice allegedly given to the Applicant’s mother about a referral to Dr Tao and the mother’s denial of receiving such referrals. Through these affidavits, both sides sought to combine specific factual assertions with existing and new evidence to construct their most persuasive legal arguments.

The Judge’s procedural directions regarding the affidavits implicitly aimed to ensure that all parties understood the basis for the proposed amendments. The Court scrutinised whether the affidavits provided sufficient explanation for the timing of the applications and whether the proposed evidence (like Dr Ford’s testimony) would introduce new, unanticipated material or merely refine existing pleadings. The detailed presentation of facts within the affidavits, alongside the medical reports, allowed the Court to assess the arguable merits and potential prejudice of the proposed amendments, ensuring a balanced consideration of the parties’ positions before the main trial.

Chapter 5: Court Orders

Prior to the ultimate hearing on the interlocutory applications, the Court issued several procedural directions to facilitate the resolution of the complex medical issues. These included the convening of multiple conclaves of medical experts to narrow the issues in dispute. A conclave of midwives prepared a joint midwifery report dated 6 January 2025. A separate conclave of general practitioners prepared a report dated 14 February 2025. Crucially, a conclave of nine medical experts was convened to opine on issues of causation, and their report was dated 4 March 2025. These orders for expert conclaves were essential for clarifying the highly technical medical aspects of the case.

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

During the hearing, the parties engaged in a vigorous debate concerning the proposed amendments to the defences. The core of the confrontation revolved around the interpretations of medical records and expert opinions. For the Kasai procedure amendments, the First Respondent contended that Dr Andrew Ford, the surgeon, would testify as a factual witness, asserting the initial success of the procedure based on his operation notes and a letter. The Applicant challenged this, raising concerns about the timing of the application to call Dr Ford and the scope of his testimony, fearing it might stray into expert evidence or contradict existing discovered material.

The Court acknowledged the critical importance of the amendments in defining the real controversy between the parties. However, the Court also expressed reservations about the timing and the potential for Dr Ford’s evidence to introduce new, potentially prejudicial, material outside the established documentary record.

The Honourable Justice McIntyre, in weighing the arguments, articulated the Court’s approach to such applications:

“Factors such as the nature and importance of the amendment to the party applying cannot be overlooked. Whilst r21 assumes some ill effects will flow from the fact of a delay that will not prevent the parties dealing with its particular effects in their case in more detail. It is the extent of the delay and the costs associated with it, together with the prejudice which might reasonably be assumed to follow and that which is shown, which are to be weighed against the grant of permission to a party to alter its case. Much may depend upon the point the litigation has reached relative to a trial when the application to amend is made. There may be cases where it may properly be concluded that a party has had sufficient opportunity to plead their case and that it is too late for a further amendment, having regard to the other party and other litigants awaiting trial dates.”

This statement underscored the Court’s balancing act between allowing parties to fully articulate their cases and managing the efficiency and fairness of litigation for all involved. The Court determined that while the explanation for delay regarding Dr Ford was unsatisfactory, the proposed amendments, if constrained to the existing discovered facts, did not introduce entirely new information and were arguably tenable.

For the “delay” amendments, the Second and Third Respondents argued that these were merely refinements of existing pleadings, not new material. The Applicant countered that these amendments lacked the particularity required by UCR 67.2, hindering the ability to respond effectively. The Court scrutinised whether the existing particulars were sufficient for the Applicant to understand the case against them.

Ultimately, the Court’s reasoning was driven by the principle of determining the real controversy between the parties, balanced against the potential for disruption and prejudice. The Judge carefully considered whether the amendments genuinely refined existing arguments rather than introducing entirely new ones and whether the timing would derail the imminent trial.

Chapter 7: Final Judgment of the Court

The Court granted the interlocutory applications, allowing the First, Second, and Third Respondents to amend their defences in line with their respective applications.

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

Special Analysis:

This case highlights the procedural complexities inherent in medical negligence litigation, particularly concerning interlocutory applications to amend pleadings shortly before trial. The decision is noteworthy for its practical application of the Aon Risk Services principles in balancing the parties’ right to articulate their case fully against the need for efficient and fair administration of justice. The Court’s nuanced stance on the admissibility and scope of Dr Ford’s potential evidence (confining it to discovered factual material) indicates a pragmatic approach to preventing late amendments from transforming into entirely new cases or expert opinion disclosures under the guise of factual testimony. This ruling serves as a crucial reminder of the judiciary’s gatekeeping function, especially in complex, multi-party litigation, to maintain the integrity of the trial process.

Judgment Points:

The Court made several specific comments and rulings of note:
* The explanation for the delay in seeking to amend, particularly regarding efforts to locate Dr Ford, was deemed “unsatisfactory.” This underscores the Court’s expectation of diligent case management.
* The Court imposed a significant limitation on Dr Ford’s potential evidence, stating it would not permit testimony that strayed into expert evidence or contradicted discovered documents without cogent reasons. This is a critical point for managing witness testimony in complex cases.
* The Court found that the “delay” amendments proposed by the Second and Third Respondents did not introduce new material but were a “refinement of existing pleadings,” indicating judicial tolerance for sharpening arguments based on existing factual disputes.
* The Court explicitly confirmed that the existing particulars in the pleadings were adequate to provide fair notice to the Applicant regarding the “delay” allegations.

Legal Basis:

The Honourable Justice McIntyre referred to and applied Rule 69.2 of the Uniform Civil Rules, which governs the amendment of claims or pleadings by consent or with leave of the Court. The foundational principles for exercising this discretion were derived from the High Court’s decision in Aon Risk Services Australia Ltd v Australian National University (2009) 239 CLR 175. This framework mandates a balancing act, considering factors such as the nature and importance of the amendment, its arguable merits, the stage of litigation, the explanation for delay, and the potential impact on the trial, costs, and public confidence in the justice system.

Evidence Chain:

The evidence relied upon by the respondents primarily consisted of the Applicant’s own Women and Children’s Hospital medical records, specifically Dr Andrew Ford’s operation notes and his letter to Professor Davidson dated 14 November 2002. These documents, though long available, formed the basis for the First Respondent’s amended defence regarding the initial success of the Kasai procedure. For the “delay” amendments, the evidence comprised the differing accounts of consultations in August 2002, as detailed in the parties’ affidavits, concerning alleged referrals to a paediatrician and the Applicant’s mother’s denials. The medical expert conclave reports provided background on causation issues, though the Court cautioned against their presumptive interpretation of Kasai failure.

Judicial Original Quotation:

In determining whether to grant leave for the Kasai procedure amendments, the Court concluded that the proposed amendments were arguable or tenable on the evidence.

“The first respondent, however, says that the answers of the conclave do not prevent the first respondent from advancing a pleading that the Kasai surgery was initially successful but impeded by recurring acute cholangitis. The basis for this submission is a contention that it appears that the experts assumed the failure of the Kasai surgery, albeit that this was not expressed to be an assumed fact in the letters of instruction. Noting that the applicant is prepared to consent to the amendment in terms of the proposed paragraph 42, I am not satisfied that the proposed amendment to paragraph 43 is not arguable or tenable.”

This statement was determinative because it clarified that the Court would not definitively rule on the ultimate merits of the proposed defence at this interlocutory stage. Instead, the threshold was whether the argument was “arguable or tenable,” which the Court found it to be, particularly when the Applicant had already consented to a related amendment in paragraph 42.

Regarding the “delay” amendments and the Applicant’s argument concerning insufficient particulars, the Court stated:

“There is clearly a significant factual dispute to be determined, however, the proposed pleadings do no more than plead a counterfactual based upon material that is already pleaded. The particulars contained in the existing pleadings are adequate. Whilst there is no specific explanation for the delay in seeking this amendment, beyond a pre-trial review of proceedings in the light of the conclaves, there is no suggestion that the amendments will impact the commencement of the trial or its length. Further, there is no evidence of additional cost to be occasioned by the amendment nor of any possible impact on public confidence. In all of the circumstances I will grant leave to the second and third respondent to amend their pleadings as set out above.”

This ruling was pivotal, as it upheld that the amendments, despite late filing and a lack of detailed explanation, sufficiently built upon existing pleadings without introducing entirely new, unparticularised claims. The Court’s focus was on whether the amendments would genuinely disrupt the trial or cause irremediable prejudice, which it found they would not, given the existing factual dispute and adequate particulars.

Analysis of the Losing Party’s Failure:

The Applicant’s objections to the amendments were not entirely successful because the Court did not find sufficient grounds to deny leave. The Applicant’s argument regarding lack of justification for delay (especially concerning Dr Ford) was noted as “unsatisfactory” by the Court but was not deemed fatal to the application. Crucially, the Court determined that the proposed amendments, particularly for the Kasai procedure, were “arguable or tenable” and did not introduce “new information” in the context of the available evidence. The Applicant’s concern about prejudice from Dr Ford’s evidence was acknowledged, but the Court indicated it would likely limit the scope of his testimony to factual matters already discovered, mitigating this risk. For the “delay” amendments, the Applicant’s contention that they lacked particularity was overcome by the Court’s finding that the amendments merely refined existing pleadings and that the existing particulars were “adequate.” The Applicant also failed to demonstrate that the amendments would cause significant disruption to the trial, additional costs, or impact public confidence.

Implications

Preparation is Key: Diligent preparation and timely filing of all legal documents are crucial. The Court scrutinises explanations for delay, even if not always fatal.
Strategic Pleadings: Legal professionals should understand that pleadings are dynamic. Even late amendments may be permitted if they refine existing arguments rather than introduce entirely new ones, demonstrating the flexibility of civil procedure.
Witness Testimony Limits: Factual witnesses, even if also experts in their field, are generally confined to providing factual evidence based on their direct involvement or records, not new expert opinions, unless specific leave is granted.
Causation Complexity: Medical negligence cases often involve intricate causation debates. Thoroughly documented records and clear expert opinions are vital for establishing or challenging the causal link between alleged negligence and harm.
Navigating Interlocutory Applications: These applications are critical procedural junctures. Understanding the Court’s balancing act between allowing parties to fully plead their case and ensuring judicial efficiency is paramount for successful litigation.

Q&A Session

Q1: What is the significance of the High Court decision in Aon Risk Services Australia Ltd v Australian National University to this case?
A1: The Aon Risk Services decision is foundational to this case as it establishes the legal principles governing applications for leave to amend pleadings in Australia. It mandates that courts undertake a “balancing act,” considering not only the immediate dispute between parties but also broader factors such as the impact of delay, costs, and prejudice on other litigants and the efficient administration of justice. In this case, Justice McIntyre explicitly applied these principles to determine whether the respondents should be granted leave to amend their defences.

Q2: Why was the Court cautious about the potential evidence of Dr Andrew Ford?
A2: The Court was cautious because Dr Ford, while the surgeon who performed the Kasai procedure, was not formally disclosed as an expert witness. The concern was that his testimony might inadvertently stray beyond factual observations (e.g., from his operation notes) into expert opinion or contradict existing discovered documents. Permitting such evidence without proper disclosure could significantly prejudice the Applicant and other parties by introducing new arguments or evidence late in the proceedings, disrupting the trial. The Court indicated it would likely limit his evidence to facts already within the discovered material.

Q3: What does it mean that the proposed amendments regarding delayed diagnosis were a “refinement of existing pleadings” and why was it important?
A3: A “refinement of existing pleadings” means the proposed amendments clarified, sharpened, or elaborated upon arguments that were already present in the original defences, rather than introducing entirely new allegations or legal bases. This was important because courts are generally more willing to grant leave for refinements, even at a late stage, as they are less likely to cause significant surprise, delay, or prejudice compared to wholly new claims. In this case, the Court found the existing particulars adequate and that the amendments merely elaborated on an already pleaded counter-factual, thereby allowing them to proceed.

Appendix: Reference for Comparable Case Judgments and Practical Guidelines

1. Practical Positioning of This Case

Case Subtype: Medical Negligence – Interlocutory Application for Amendment of Defence – Causation & Delayed Diagnosis
Judgment Nature Definition: Interlocutory Judgment

2. Self-examination of Core Statutory Elements

⑦ Personal Injury and Compensation

Core Test (Negligence under the Civil Liability Act):

Was there a Duty of Care owed? This requires establishing that the defendant owed a legal obligation to exercise reasonable care to avoid a foreseeable risk of harm to the plaintiff. For medical practitioners, a duty of care is generally owed to patients.
Was there a Breach of Duty (was the risk foreseeable and not insignificant)? This involves demonstrating that a reasonable person in the defendant’s position would have foreseen the risk and taken precautions, and that the defendant failed to do so. The risk must be “not insignificant” and the breach involves a failure to meet the standard of care of a reasonably competent professional (Section 5O of the Civil Liability Act 2002 (SA)).
Did the breach cause the injury (Causation)? This is a two-part test (Section 5D of the Civil Liability Act 2002 (SA)):
- Factual Causation: Was the negligence a necessary condition of the occurrence of the harm (the “but for” test)? In complex medical cases like this, it often involves counterfactual analysis: “but for” the delay/misdiagnosis, would the Kasai procedure have been successful or the liver transplant avoided?
- Scope of Liability: Is it appropriate for the scope of the negligent person’s liability to extend to the harm so caused? This considers legal policy and common sense. In cases of delayed diagnosis, assessing how the delay contributed to a worse outcome is a critical aspect of causation.

Core Test (Damages):

Does the Whole Person Impairment (WPI) exceed the statutory threshold? In various jurisdictions, there are thresholds for non-economic loss (e.g., pain and suffering, loss of enjoyment of life). For instance, in some Australian states, a certain percentage of WPI might be required before non-economic damages can be awarded.
Is there contributory negligence? This assesses whether the plaintiff’s own negligence contributed to their harm. If established, damages may be reduced proportionally. In this case, the respondents’ proposed amendments regarding the Applicant’s mother’s alleged failure to follow referrals raised the possibility of contributory negligence, which could impact the assessment of damages.

⑨ Civil Litigation and Dispute Resolution

Core Test:

Has the Limitation Period expired? This refers to the statutory time limits within which a legal action must be commenced. Generally, for personal injury in South Australia, this is 3 years from the date the cause of action is discoverable.
Does the Court have Jurisdiction over the matter? This ensures the court has the legal authority to hear the case (e.g., Supreme Court for high value or complex matters, District Court for medium value, Magistrates Court for lower value).
Has the duty of Discovery/Disclosure of evidence been satisfied? Parties are required to disclose all relevant documents to each other, forming a crucial aspect of procedural fairness and ensuring no party is ambushed at trial. The debate over Dr Ford’s evidence highlights the importance of timely and comprehensive disclosure.

3. Equitable Remedies and Alternative Claims

If dealing with [Civil / Commercial / Property / Family / Estate] matters:

Promissory / Proprietary Estoppel:

Did the other party make a clear and unequivocal promise or representation (e.g., “this property will be yours”)? In a medical context, this might relate to clear assurances of a particular outcome or standard of care beyond general expectations.
Did you act in detrimental reliance on that promise (e.g., renovating the property, resigning from a job)? The Applicant might argue reliance on implied promises of timely and competent medical care.
Would it be unconscionable for the other party to resile from that promise? The Court would assess whether it would be against good conscience for the medical providers to retract any specific representations given.
Result Reference: Even without a written contract, Equity may “estop” the other party from going back on their word, potentially enforcing an expectation or compensating for detriment.

Unjust Enrichment / Constructive Trust:

Has the other party received a benefit (money or labor) at your expense? Is it against conscience for them to retain that benefit without payment? In a medical setting, this is less directly applicable but could theoretically arise if, for instance, a service was rendered inefficiently, leading to undue benefit for the provider at the patient’s further expense.
Result Reference: The Court may order the restitution of the benefit or declare that you hold a beneficial interest in the asset via a Constructive Trust.

4. Access Thresholds and Exceptional Circumstances

Regular Thresholds:

Limitation period for personal injury claims: In South Australia, generally 3 years from the date the cause of action is discoverable.
Pleading amendment timeliness: Applications to amend pleadings, especially once a trial date is set, carry a relatively high risk of rejection without compelling reasons for delay.

Exceptional Channels (Crucial):

Personal Injury: Limitation period expired? Extensions may be granted upon the discovery of latent damage (e.g., a medical condition that only manifests years later) or in cases of legal incapacity (e.g., minors or persons with a disability). Given the Applicant’s age at the time of the alleged negligence, the usual limitation periods would likely be managed by the litigation guardian.
Pleading Amendments: The Aon Risk Services principles themselves embody an “exceptional channel” for late amendments. Even with unsatisfactory explanations for delay, leave may be granted if the amendments are crucial to determining the “real controversy” between the parties, are arguable, and do not cause disproportionate prejudice or disrupt the trial significantly.
Suggestion: Do not abandon a potential claim simply because you do not meet the standard time or conditions. Carefully compare your circumstances against the exceptions above, as they are often the key to successfully filing a case.

5. Guidelines for Judicial and Legal Citation

Citation Angle: It is recommended to cite this case in legal submissions or debates involving interlocutory applications to amend pleadings in complex medical negligence cases, particularly where there are issues of late filing, unsatisfactory explanations for delay, and the scope of factual versus expert witness testimony.

Citation Method:
* As Positive Support: When your matter involves an application to amend pleadings to clarify causation arguments based on existing discovered medical records, citing this authority can strengthen your argument that such refinements are permissible to determine the “real controversy” and do not necessarily introduce “new material,” provided the arguments are tenable and do not unduly disrupt the trial.
* As a Distinguishing Reference: If the opposing party cites this case to argue for extensive late amendments, you should emphasize the uniqueness of the current matter where proposed evidence might stray into undisclosed expert testimony or introduce claims lacking sufficient particularity, arguing that this precedent supports limiting such evidence or denying amendments that genuinely breach procedural fairness.

Anonymisation Rule: Do not use the real names of the parties; strictly use professional procedural titles such as Applicant / Respondent or Appellant / Respondent.

Conclusion

This judgment serves as a robust affirmation of the South Australian Supreme Court’s commitment to procedural fairness and judicial efficiency in complex litigation. It underscores that while diligence in case management is expected, the Court retains discretion to allow necessary amendments to ensure the true legal controversy is determined. The decision highlights the delicate balance between preventing trial disruption and upholding a party’s right to fully present an arguable case, even if amendments are sought at a late stage.

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 Supreme Court of South Australia (HANBY v STATE OF SA & ORS [2025] SASC 84), 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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