Stalking Consultation Paper

3. Understanding and responding to stalking

Introduction

3.1 Victoria Police is responsible for preventing crime and detecting and investigating offences, including stalking. A comprehensive policing response to stalking places the victim survivor at the centre and focuses on:

• prevention of future harm

• holding people who commit stalking accountable for their conduct

• reducing reoffending and severe outcomes

• making appropriate referrals to address the service needs of victim survivors, as well as those who have committed stalking.

3.2 In this chapter we ask if police are meeting these aims, and if not, how we can improve the police response to stalking.

3.3 In the context of family violence, a risk management framework was developed to enable police, practitioners, and organisations to identify risk of serious harm in family violence and provide helpful and timely responses to victim survivors. The framework is used by a wide range of professionals who come into contact with victim survivors of family violence. Currently, identifying stalking and the risk of serious harm is almost the exclusive responsibility of Victoria Police. We ask whether there should be a multi-agency risk management framework for stalking.

How should agencies identify the risk of serious harm posed by a person committing stalking?

Indicators of risk of serious harm in stalking

3.4 Stalking is very serious and can cause lasting psychological harm. However not all stalking leads to physical violence. We are interested to know how police can identify people who pose a real risk of causing serious injury, significant ongoing harm, or death during the course of their stalking.

3.5 There is limited statistical information about risk of serious harm and recidivism in the context of stalking as research is still emerging. However, research has shown that it is difficult for police to assess and manage the risks of serious harm associated with stalking.[87] The primary challenge for frontline police is identifying the course of conduct constituting stalking, and understanding what factors may indicate the stalking behaviour is likely to either continue or escalate.

3.6 Factors associated with increased risk of serious outcomes include:[88]

• Relationship type (specifically former intimate partner), explicit threats, and previous property damage are associated with a higher likelihood of stalking violence.[89]

• Psychiatric diagnosis, personality disorder, substance misuse, criminal history, a prior acquaintanceship and erotomanic delusions may predict stalking recurrence.[90]

• Previous acquaintanceship and the presence of delusional beliefs may predict stalking persistence.[91]

• Stalking committed by a stranger that is brief in duration may also involve increased risks of physical and/or sexual violence.[92]

3.7 Identifying risk of serious harm is difficult because stalking usually involves behaviours that would otherwise be considered non-threatening, non-violent, and even legal. For example, in a non-stalking context, leaving a gift at someone’s house might be a thoughtful gesture. But in a stalking situation, it could be threatening.

How can risk of serious harm be assessed?

3.8 The evidence base on policing stalking in Victoria (and Australia) is limited. Evidence indicates that police in other countries ‘often underestimate the severity of stalking and fail to respond adequately to protect victims’.[93] Research suggests that police can lack training and resources to conduct the kind of assessments necessary to identify stalking cases that present increased risk of serious harm.[94] Research also suggests that ‘police find it challenging to respond to stalking in a timely way’.[95]

3.9 Dedicated training of police on the dynamics of stalking and risk management is being implemented in international jurisdictions.[96]

3.10 Actuarial risk assessment tools have been developed to support professional judgment of risk of serious harm, also referred to as ‘structured professional judgment’.[97] ‘Actuarial risk assessment’ refers to the practice of screening and assessment to identify risk, consistent with established evidence-based risk factors (such as those outlined above in 3.6).[98] It involves a statistical method of estimating risk which is considered more accurate when used in conjunction with clinical or professional judgment, rather than such judgment alone.

3.11 However, actuarial risk assessment tools have been the subject of criticism. For example, actuarial risk assessment tools are typically ‘developed and tested on predominantly non-Indigenous populations’ and can be biased against Indigenous and culturally and linguistically diverse communities.[99] Indigenous people ‘have higher rates of childhood abuse victimisation and early substance abuse, both of which are included as factors associated with high-risk status in many risk assessment instruments’.[100] This means that Aboriginal people are more likely to be classified as high-risk than non-Aboriginal people.

3.12 Given the relatively low prevalence rates of stalking, an actuarial risk tool may not be an accurate method of assessing the risks of serious harm associated with stalking. They are also not a certain measure of risk of serious harm.[101]

3.13 Research suggests that risk assessment should be supplemented with person-centred information. As identified in the family violence context, a risk tool alone cannot resolve the complexity involved in accurately assessing and managing risk of serious harm.[102]

How is risk of serious harm assessed and managed in family violence?

3.14 In the family violence context, the multi-agency risk assessment and management (MARAM) framework was designed to support relevant services to identify, assess and manage family violence risk. There are three levels of MARAM, which define roles and responsibilities assessing and managing risk:[103]

• Level 1 – Screening and identification: provides guidance for practitioners who may come in contact with family violence victim survivors whilst providing universal services. This level requires respectful, sensitive and safe engagement, to enable identification of family violence and for seeking consultation for comprehensive risk assessment, risk management and referrals.

• Level 2 – Brief and Intermediate: provides guidance for practitioners who have some contact with people experiencing family violence but where responding to family violence is not their core function. This level requires the same processes as Level 1 but also involves intermediate risk assessment and management.

• Level 3 – Comprehensive: provides guidance for specialist family violence practitioners and involves all aspects of Levels 1 and 2, but requires comprehensive risk assessment, risk management and safety planning.

3.15 Victoria Police members are also required to complete a Family Violence Report (‘FVR(L17)’) when attending an incident (such as family violence, interfamilial-related sexual offences, and child abuse). An FVR(L17) is an actuarial risk assessment and risk management tool.[104]

3.16 The approach to understanding family violence is set out in the MARAM Practice Guides. The approach to risk assessment combines professional judgment (of practitioners and/or police), the victim survivor’s own assessment of level of risk and evidence-based risk factors. The family violence system also involves risk assessment and management panels (RAMPs), for managing complex risk. A RAMP is ‘a formally convened meeting, held at a local level, of nine key agencies and organisations that contribute to the safety of women and children experiencing serious and imminent threat from family violence.’[105]

No equivalent framework exists for stalking.

3.17 We ask whether the responsibility for comprehensive risk assessment and risk management should be shared and integrated with other relevant services such as health, legal, victim support and the courts.[106] A specific risk assessment tool for use by multiple services, such as the MARAM framework, may be required.

Questions

2 Should a risk assessment framework be developed to help police and courts identify the course of conduct and manage risk of serious harm in the context of stalking? If so, how should it work?

3 What else might help agencies to identify the risk of serious harm in a stalking situation? For example, should there be special training or guidelines, or expert advice?

What information do police need to assess the risk of serious harm posed by a person committing stalking?

Getting the whole story from the victim survivor

3.18 If police do not act on complaints of stalking, it can place people at risk of serious harm, especially where the victim survivor is reporting stalking that is persistent and/or escalating.[107]

3.19 If people experiencing stalking report only a single incident in a wider pattern of stalking, these cases might not be identified as stalking by police.[108] For police to be able to accurately assess risk of serious harm, they need to ask victim survivors the right questions to elicit the whole story.[109]

3.20 The ‘whole story’ investigative framework is part of the Victoria Police five-year strategic plan to address family violence, sexual offences and child abuse.[110] It is an approach developed for the investigation of sexual offences, recognising that the context surrounding the abuse was often missing from police statements.[111] Questions about context such as the relationship between the victim survivor and person who committed the sexual offence, the power dynamics, and any other circumstances about the events leading up to the abuse, were generally not asked by police.[112] The ‘whole story’ framework requires investigators to ask the right questions to understand the whole story of how the abuse occurred, rather than focusing on individual details.[113]

3.21 A key issue for police is identifying stalking behaviour (the course of conduct). The international evidence suggests police tend to rely on an incident-based model for responding to stalking. Traditional incident-based responses from police may not be suitable for stalking which involves a course of conduct.[114]

Question

4 What approaches or techniques should be used by law enforcement agencies when investigating stalking complaints?

Getting the whole story from the rest of the system

3.22 Police might not be aware that a person committing stalking has interacted with other agencies or that the victim survivor has sought help from other agencies. This might mean that police do not have a complete picture when completing their risk assessment.

3.23 Victim survivors might be required to retell their story with each new stalking incident. The Royal Commission into Family Violence found that information sharing may reduce the need for victim survivors to retell their story to multiple service providers.[115]

3.24 The Family Violence Protection Act 2008 (Vic) (FVP Act) contains a legislative regime for information sharing in family violence situations. In the context of family violence, information-sharing entities must use the MARAM framework under the Family Violence Information Sharing Scheme to identify, assess and manage family violence risk to children and adults.[116] This information sharing framework was introduced in response to findings from the Royal Commission into Family Violence that the range of specialist services likely to be involved in working with a victim, perpetrator and children required those services to ‘pool’ information to fully inform risk assessment.[117]

3.25 No equivalent regime exists under the Personal Safety Intervention Orders Act. Information sharing regimes have implications for people’s privacy and require substantial resources to implement. We are interested to understand whether there are good reasons for a similar regime in the context of stalking.

Question

5 In the family violence intervention order system, information sharing is allowed. Should there be a similar framework for information sharing between agencies providing services for stalking? If so, how should it work?

Who should conduct in-depth risk assessments?

3.26 Once a front-line police officer has identified a concerning course of conduct, they might need to refer the matter to a specialist unit for in-depth assessment.

3.27 A specialised, multi-disciplinary stalking unit could support police to classify stalking correctly, triage and assess risk of serious harm, make referrals, and properly investigate stalking.

3.28 In the United Kingdom, the Stalking Threat Assessment Centre is a multi-agency specialist unit dedicated to addressing stalking. It is a partnership between police, court services, and other non-government services. It improves responses to stalking across the criminal justice system and the health sector through increased reporting, victim survivor advocacy, better criminal justice responses and rehabilitative interventions.[118]

3.29 Because a specialist, multi-disciplinary approach is time and resource intensive, only cases categorised as posing a risk of serious harm should be referred to it, so that it uses its resources ‘where they can have the most impact’.[119]

What actions can police take?

3.30 Once Victoria Police have identified a course of conduct that may amount to stalking, what actions can they take? Their options are:

• no action

• advise the person being stalked to apply for a personal safety intervention order (PSIO) (PSIOs will be discussed in detail in the next chapter)

• apply for a PSIO on behalf of the person being stalked

• file criminal charges where appropriate, including for breaches of PSIOs

• refer people being stalked to support services.

3.31 We will discuss each of these actions in turn.

No action

3.32 Police operate with limited resources. They are often asked to prioritise their time between multiple allegations of criminal activity. Not every matter is followed through to the same extent.

3.33 At present, it can be challenging for police to determine whether a complaint represents stalking compared with, for example, a dispute that would be better resolved by mediation or some other intervention.

3.34 This problem can be compounded by the fact that the person may also not be aware of all the stalking that has occurred or mention all of the stalking that has occurred.

3.35 In such cases, police might give general advice (eg: block the person committing stalking on social media) and tell the victim survivor to come back if the problem gets worse.

3.36 The risk is that the stalking might continue or escalate.

Advise the victim survivor to apply for a personal safety intervention order

3.37 Police can advise the person being stalked to apply for a PSIO to protect their safety.

3.38 A PSIO can provide reassurance that there is a level of protection in place. It can also prompt police action if it is breached.

3.39 However, it can be intimidating for the person being stalked to go to court. There are few free legal services to assist them with their application.

3.40 Victim survivors can also face barriers to accessing courts. For example, the courts might not be experienced as culturally safe.

3.41 If the person being stalked is the applicant for the PSIO, this could also escalate the stalking behaviour.

3.42 Although there is little evidence of how effective the PSIO system is in reducing the crime of stalking, international research suggests that even where there are court interventions in place, people who commit stalking against a former partner are more likely to reoffend than those who commit stalking against a non-partner.[120] This may suggest that protection orders have some impact on reducing stalking. But in other cases, protection orders may give the person being stalked a false sense of security, or enrage the person committing stalking, resulting in further and increased safety risks.

Apply for a personal safety intervention order on behalf of the victim survivor

3.43 Police have the power to apply for a PSIO on behalf of the person being stalked.

3.44 Police applications can take the pressure off the victim survivor to be their own advocate. They can reduce the risk of the victim survivor being blamed by the person stalking for the intervention order being imposed.

3.45 However, surveys show that victims of stalking often perceive that the intervention order system does not protect them.[121]

3.46 Due to the lack of data, it is not known whether, or in what circumstances, PSIOs actually protect victims. And if they do, it is not known whether their effectiveness depends on:

• the motivation of the person who is stalking (eg: revenge, relationship-seeking)

• characteristics of the person who is stalking (eg: drug or alcohol issues, mental health issue, or cognitive impairment/intellectual disability).

3.47 It is also not known whether, or in what circumstances, PSIOs give people who are stalked a false sense of security because they believe they are protected by the order.

File criminal charges

3.48 Police can investigate and file criminal charges where they believe there is enough evidence. This is explored in Chapter 5.

3.49 Criminal charges can be pursued alongside a PSIO application.

Refer the victim survivor to services

3.50 Victim survivors of stalking can be traumatised by their experience and might need help with safety planning. Referrals to support services can help victim survivors recover. This is covered in Chapter 6.

What guidance helps police to decide which action to take?

3.51 Police have limited written guidance on how to manage non-family violence stalking offences.

3.52 By contrast, Victoria Police has a Code of Practice to guide decision making in situations of family violence.[122]

3.53 The family violence Code of Practice requires police to respond to all reports of family violence by thoroughly assessing and managing risk and applying for civil protection orders. The Code requires that police:

• apply for Family Violence Intervention Orders (FVIO) or Family Violence Safety Notices (FVSN)

• investigate and file criminal charges where appropriate, including for contraventions of FVIO and FVSN

• increase successful prosecutions

• minimise the trauma experienced by victim survivors and the support people during the process of police intervention

• make appropriate referrals.[123]

Question

6 Should there be a specific police Code of Practice for reports of stalking? If so, what should it cover?

Should there be options for urgent protection?

3.54 Under the Family Violence Protection Act police can make police can make an FVSN, which provides urgent and temporary protection until the court can make an interim or final intervention order. There is no equivalent provision in the PSIO Act.

3.55 A police officer who responds in person to a family violence incident may apply to a more senior officer for a FVSN if they believe on reasonable grounds that a FVSN is necessary to:

• ensure the safety of the person who needs protection

• preserve property of that person

• protect a child who has been subjected to family violence by the person using family violence.[124]

3.56 It is an offence to contravene a FVSN.[125]

3.57 Where an FVSN is issued, it is considered an application for an FVIO by the police officer who applied for it, and a summons for the person using family violence to attend court.[126]

3.58 FVSNs were introduced to address the need to put urgent protection in place for those experiencing family violence until a matter can come before a court. They complement police powers to arrest someone who has committed a criminal offence as a form of family violence.

3.59 Under the PSIO Act, police have the power to apply to the court for a warrant to arrest the respondent if the court believes on reasonable grounds it is necessary to keep the victim survivor safe, to preserve their property or to ensure that the respondent attends court.[127] If the court grants the application, police can then arrest the respondent and bail them with conditions that protect the victim survivor until the matter can be brought before a magistrate.[128]

3.60 There is a risk if that FVSNs were introduced in the PSIO context, police might use FVSNs instead of referring matters to mediation where mediation is more appropriate. Aggrieved members of the public might view FVSNs as a more acceptable response than being told they should mediate their problems. FVSNs might therefore be an ‘easier sell’ for time-poor police than persuading feuding neighbours to try mediation.

3.61 If FVSNs were introduced in the PSIO system it creates a risk that more interpersonal disputes might end up being managed through intervention orders, rather than being resolved by mediation.

3.62 A flood of PSIOs into the court system that would be better resolved by mediation might hide stalking cases, where there is a risk of escalation or continuation, that need careful court attention.

3.63 As with family violence, police may incorrectly identify the victim survivor as the person committing stalking. This might mean that the victim survivor is the one that must comply with the FVSN, not the person using stalking, until the matter can be brought before a magistrate.

Question

7 Should there be an option under the Personal Safety Intervention Orders Act 2010 for police to be able to issue the equivalent of a Family Violence Safety Notice? Why/why not?


  1. Troy E McEwan et al, ‘Measuring Stalking: the Development and Evaluation of the Stalking Assessment Indices (SAI)’ (2020) July Psychiatry, Psychology and Law 1 <https://doi.org/10.1080/13218719.2020.1787904>.

  2. Troy McEwan, Paul E Mullen and Rosemary Purcell, ‘Identifying Risk Factors in Stalking: A Review of Current Research’ (2007) 30(1) International Journal of Law and Psychiatry 1.

  3. Troy E McEwan et al, ‘Risk Factors for Stalking Violence, Persistence, and Recurrence’ (2017) 28(1) Journal of Forensic Psychiatry & Psychology 38.

  4. Troy E McEwan et al, ‘Risk Factors for Stalking Recidivism in a Dutch Community Forensic Mental Health Sample’ (2020) 19(2) International Journal of Forensic Mental Health 127; Troy E McEwan et al, ‘Risk Factors for Stalking Violence, Persistence, and Recurrence’ (2017) 28(1) Journal of Forensic Psychiatry & Psychology 38; Troy McEwan, Paul E Mullen and Rosemary Purcell, ‘Identifying Risk Factors in Stalking: A Review of Current Research’ (2007) 30(1) International Journal of Law and Psychiatry 1.

  5. Troy E McEwan et al, ‘Risk Factors for Stalking Violence, Persistence, and Recurrence’ (2017) 28(1) Journal of Forensic Psychiatry & Psychology 38.

  6. Troy McEwan, Paul E Mullen and Rosemary Purcell, ‘Identifying Risk Factors in Stalking: A Review of Current Research’ (2007) 30(1) International Journal of Law and Psychiatry 1.

  7. Kellie R Lynch and TK Logan, ‘Police Officers’ Attitudes and Challenges With Charging Stalking’ (2015) 30(6) Violence and Victims 1037; TE McEwan, ‘Stalking Threat and Risk Assessment’ in J Reid Meloy and Jens Hoffman (eds), International Handbook of Threat Assessment (Oxford University Press, 2nd ed, 2021) 3; Lorraine P Sheridan, Adrian J Scott and Amy M Campbell, ‘Perceptions and Experiences of Intrusive Behavior and Stalking: Comparing LGBTIQ and Heterosexual Groups’ (2019) 34(7) Journal of Interpersonal Violence 1388; Holly Taylor-Dunn, Erica Bowen and Elizabeth A Gilchrist, ‘Reporting Harassment and Stalking to the Police: A Qualitative Study of Victims’ Experiences’ (2018) 36(11-12) Journal of Interpersonal Violence 1 <https://doi.org/10.1177/0886260518811423>.

  8. TE McEwan, ‘Stalking Threat and Risk Assessment’ in J Reid Meloy and Jens Hoffman (eds), International Handbook of Threat Assessment (Oxford University Press, 2nd ed, 2021).

  9. Troy E McEwan et al, ‘Risk Factors for Stalking Recidivism in a Dutch Community Forensic Mental Health Sample’ (2020) 19(2) International Journal of Forensic Mental Health 127, 139.

  10. Cleo Brandt and Bianca Voerman, ‘The Dutch Model: A New Approach to Policing Stalking’ in Psycho-Criminological Approaches to Stalking Behaviour—An International Perspective (Wiley, In Press); TE McEwan, ‘Stalking Threat and Risk Assessment’ in J Reid Meloy and Jens Hoffman (eds), International Handbook of Threat Assessment (Oxford University Press, 2nd ed, 2021).

  11. Bernadette McSherry, ‘Risk Assessment, Predictive Algorithms and Preventive Justice’ in John Pratt and Jordan Anderson (eds), Criminal Justice and the Revolt Against Uncertainty (Palgrave Macmillan, 2020).

  12. ‘Stalking Threat Assessment Centre’, Mayor of London: London Assembly (Web Page, 4 November 2019) <https://www.london.gov.uk/questions/2019/20366>.

  13. Bernadette McSherry, ‘Risk Assessment, Predictive Algorithms and Preventive Justice’ (Palgrave Macmillan, 2020).

  14. Ibid.

  15. Ibid.

  16. Jude McCulloch et al, Review of the Family Violence Risk Assessment and Risk Management Framework (CRAF): Final Report (School of Social Sciences, Monash University, September 2016).

  17. Family Violence Multi-Agency Risk Assessment and Management Framework— DHHS Service Providers (Web Page) <https://providers.dffh.vic.gov.au/family-violence-risk-assessment-and-risk-management-framework>.

  18. Victoria Police, Information for External Stakeholders, the New Family Violence Report L17 (Factsheet,March 2019) <https://www.nifvs.org.au/wp-content/uploads/2019/04/Vic-Pol-External-Stakeholders-Information-Sheet-re-L17s.pdf>; Victorian Government, The Orange Door Service Model (Report, December 2019) <http://www.vic.gov.au/orange-door-service-model>.

  19. Families Fairness and Housing (Vic),Family Violence Multi-Agency Risk Assessment and Management Framework’, Children, Youth & Families (Web Page) <https://providers.dffh.vic.gov.au/family-violence-risk-assessment-and-risk-management-framework>.

  20. Ibid.

  21. Fawn T Ngo, ‘Stalking Victimization: Examining the Impact of Police Action and Inaction on Victim-Reported Outcome’ (2020) 35(2) Journal of Police and Criminal Psychology 146.

  22. Troy E McEwan et al, ‘Measuring Stalking—the Development and Evaluation of the Stalking Assessment Indices (SAI)’ (2020) July Psychiatry, Psychology and Law 1 <https://doi.org/10.1080/13218719.2020.1787904>.

  23. Patrick Tidmarsh, ‘Training Sexual Crime Investigators to Get the “Whole Story”’ (PhD Thesis, Deakin University, 2016) <http://dro.deakin.edu.au/eserv/DU:30102808/tidmarsh-training-2017.pdf>; Patrick Tidmarsh, Martine Powell and Elli Darwinkel, ‘Whole Story: A New Framework for Conducting Investigative Interviews about Sexual Assault’ (2012) 4(2) II-RP Journal 35; Patrick Tidmarsh, Stefanie Sharman and Gemma Hamilton, ‘The Effect of Specialist Training on Sexual Assault Investigators’ Questioning and Use of Relationship Evidence’ (2021) Journal of Police and Criminal Psychology <https://doi.org/10.1007/s11896-021-09446-x>.

  24. Victoria Police, ‘Family Violence, Sexual Offences and Child Abuse Strategy’, Policy and Publications (Web Page, June 2021) <http://www.police.vic.gov.au/family-violence-sexual-offences-and-child-abuse-strategy>.

  25. Patrick Tidmarsh, ‘Training Sexual Crime Investigators to Get the “Whole Story”’ (PhD Thesis, Deakin University, 2016) <http://dro.deakin.edu.au/eserv/DU:30102808/tidmarsh-training-2017.pdf>.

  26. Nicole Brady, ‘Telling the Whole Truth’, The Age (Online, 29 September 2012) <https://www.theage.com.au/national/victoria/telling-the-whole-truth-20120929-26sft.html>.

  27. Patrick Tidmarsh, Stefanie Sharman and Gemma Hamilton, ‘Police Officers’ Perceptions of Specialist Training, Skills and Qualities Needed to Investigate Sexual Crime’ (2021) 22(1) Police Practice and Research 475.

  28. Patrick Q Brady and Matt R Nobles, ‘The Dark Figure of Stalking—Examining Law Enforcement Response’ (2017) 32(20) Journal of Interpersonal Violence 3149.

  29. Royal Commission into Family Violence: Report and Recommendations (Final Report, March 2016) <http://rcfv.archive.royalcommission.vic.gov.au/Report-Recommendations.html>.

  30. Family Safety Victoria, Family Violence Information Sharing Scheme (Guidance for Information Sharing Entities, September 2018) <https://www.vic.gov.au/sites/default/files/2019-01/Ministerial%20Guidelines%20-%20Family%20Violence%20Information%20Sharing%20Scheme.pdf>.

  31. Royal Commission into Family Violence: Report and Recommendations (Final Report, March 2016) 19–20 <http://rcfv.archive.royalcommission.vic.gov.au/Report-Recommendations.html>.

  32. ‘Stalking Threat Assessment Centre’, Mayor of London: London Assembly (Web Page, 4 November 2019) <https://www.london.gov.uk/questions/2019/20366>.

  33. Troy E McEwan, Stuart Bateson and Susanne Strand, ‘Improving Police Risk Assessment and Management of Family Violence through a Collaboration between Law Enforcement, Forensic Mental Health and Academia’ (2017) 3(2) Journal of Criminological Research, Policy and Practice 119.

  34. Patrick Q Brady and Bradford W Reyns, ‘A Focal Concerns Perspective on Prosecutorial Decision Making in Cases of Intimate Partner Stalking’ (2020) 47(6) Criminal Justice and Behavior 733.

  35. Paul E Mullen, Michele Pathé and Rosemary Purcell, Stalkers and Their Victims (Cambridge University Press, 2008); Michele Pathé, Rachel Mackenzie and Paul Mullen, ‘Stalking by Law: Damaging Victims and Rewarding Offenders’ (2004) 12(1) Journal of Law and Medicine 103.

  36. Victoria Police, ‘Code of Practice for the Investigation of Family Violence’, Policy and Publications (Web Page, June 2021) <http://www.police.vic.gov.au/code-practice-investigation-family-violence>.

  37. Ibid.

  38. Family Violence Protection Act 2008 (Vic) s24.

  39. Ibid s37(2).

  40. Ibid s31(1).

  41. Personal Safety Intervention Orders Act 2010 (Vic) s 21(1).

  42. Ibid s 21(2).

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