Bieganski 1993 FamCA 51

The Full Court ruled that in circumstances where abuse has occurred or where there is an unacceptable risk of abuse, access should be suspended until such time as the parent requesting access can show that there is no longer an unacceptable risk in access re-commencing.  In some cases this will involve an acknowledgement by the parent requesting access that the abuse has occurred, together with evidence of appropriate treatment (therapy for parent).  In most cases, other family members must have the opportunity to resolve the effects of the trauma on the children and the children must have the opportunity to recover from the effects of any such abuse.