The mere making and entry of a consent order that records a compromise of farm debt proceedings does not constitute 'enforcement action' in relation to a farm mortgage within the meaning of s 4 of the Farm Debt Mediation Act 1994 (NSW), even where the consent order records a new charge over property. A complaint directed at enforcement consequences flowing from a consent order, rather than the circumstances of its making, does not provide a basis for setting aside the consent order under UCPR r 36.15(1).
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