The case illustrates the volume and pattern of proceedings sufficient to satisfy the test of habitual and persistent institution of vexatious proceedings under s 3 of the Vexatious Proceedings Restriction Act 1930 (WA). A pattern of instituting proceedings that are not pressed to conclusion, repeated complaints on the same grounds after earlier dismissals, and proceedings directed at persons carrying out their professional or statutory duties may together satisfy the statutory criteria. The discretion to grant a restrictive order may be exercised having regard to the harm caused to respondents, the cost of defending proceedings, and the litigant's continued threats of further vexatious proceedings.
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