The definition of 'intimidation' in s 7 of the Crimes (Domestic and Personal Violence) Act 2007 (NSW) does not require the conduct to be undertaken in the physical presence of the victim or that there be direct communication between perpetrator and victim; posting material online that is brought to the victim's attention through intermediaries can suffice. The two-stage show cause test from Tikomaimaleya was applied, with the Court declining to proceed to the unacceptable risk stage where cause was not shown.
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