The phrase 'any relevant circumstances' in s 90(2) of the Children and Young Persons (Care and Protection) Act 1998 (NSW) is not limited to the circumstances forming the basis for the original care order but extends to any circumstances relevant to the child's safety, welfare and well-being. The Director-General has standing to apply for variation of care orders under s 90 even after the expiry of orders allocating parental responsibility to that officer, because standing derives from the power under s 34 to act upon forming an opinion that a child is in need of care and protection. Issue estoppel does not preclude re-examination of earlier findings in variation proceedings under s 90 where there has been a significant change in relevant circumstances. An unresolved question remains as to the limits of s 69ZK of the Family Law Act 1975 (Cth) in preserving State court jurisdiction under child welfare laws where no State welfare authority is involved.
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