Harm to a third party (including life-threatening harm to a close relative of an offender) is not, without a demonstrated link to the administration of justice, a relevant consideration for a non-publication order under s 111 of the Evidence (Miscellaneous Provisions) Act 1991 (ACT) or the court's inherent jurisdiction, particularly after criminal proceedings have been finalised. The cases recognising 'safety of persons' as a category (Witness v Marsden, D1 v P1, Kaplan) were distinguished on the basis that they involved ongoing proceedings or specific statutory provisions not present in the ACT.
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