Rice & Asplund 1979 FLC
The Appeal Court ruled that it should not lightly entertain an application to reverse an earlier custody order (change final order). To do so would invite endless litigation for change is an ever present factor in human affairs. The court would need to be satisfied by the applicant that, to quote Barber J., there is some changed circumstances that would justify such a serious step, some new factor arising or some material factor which was not disclosed at the previous hearing which would have been important.
The Rice and Asplund case established that a final order can be reviewed only if it is established that there have been significantly changed circumstances since the final order was made.