Sullivan v Gordon is not limited to cases involving an obligation to care for young dependent children; a plaintiff's accident-caused need compensable pursuant to Griffiths v Kerkemeyer may extend to others towards whom the plaintiff has at least a moral obligation, including a spouse and adult children. Hodgson JA's 'fair give and take of family life' approach is not inconsistent with Sullivan v Gordon but addresses a different factual scenario. The transitional provision in cl 9(1) of Schedule 6 Part 18C of the Workers Compensation Act 1987 (NSW) precludes reliance on s 44(1)(d1) of the District Court Act 1973 (NSW) for proceedings commenced before 1 January 2002.
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