A v Schulberg & Ors [2014] VSC 180 saw the court consider, on an interlocutory basis, the question of whether an individual plaintiff can be compelled to join group proceeding under Victorian law. At [18] the Court said:

I see nothing in this case that would permit this Court, acting judicially, to compel the plaintiff in the individual proceeding to re-join the group and be bound by the result of any application to approve the compromise of the proposed settlement.