The Full Court of the Family Court held in Rice & Asplund (1979) FLC 90-725 that unless a party can establish a significant change in circumstances since an earlier parenting order was made, the matter should not be reopened.

The seminal case of Rice & Asplund established the rule that the court will only revisit final parenting orders where there has been a significant change in circumstances. In Searson & Searson, the Full Court considered and applied this rule in the context of a mother who wished to relocate with the children to live interstate with her new partner.

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