The Court held that non-violent breaches of domestic violence orders will not automatically be characterised as 'family violence' under Direction 110 paragraph 8.2 unless they involved threatened or actual violence, coercion/control, or caused fear. Additionally, when assessing risk under paragraph 8.1.2, a Tribunal finding of a 'real risk' of reoffending satisfies the requirement to consider likelihood without needing to assign a specific risk category.
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