Following a complaint about a report written for Centrelink rather than for a Court, but against the background of family law proceedings, conditions were imposed on the registration of a psychologist by the Psychology Board of Australia. An appeal was brought by the psychologist in respect of those conditions: Eastwood v Psychology Board of Australia  ACAT 52.
The complaint focused in part on the psychologist’s report reference to “parental alienation syndrome”, which was not a recognised psychological disorder according to DSM-V, in saying that the patient “loves his children, they have been turned against him methodically (aka Parental Alienation Synd) he now is only seeing one child the others only occasionally will talk to him – this affects him on a regular + fluctuating basis””  & . It also focused on a statement in the report to the effect that “…(the client’s) wife destroyed him and took everything he had including turning his children against him – this is the worst nasty divorce I have encountered – he is shattered by it.”: .
The Tribunal at  commented that the report:
…attributes fault and deliberately dishonourable behavior factually to the complainant, going beyond opinion or reasonable inference. It uses emotive, extreme and exaggerated language. It does not purport to give an objective assessment or opinion of the situation. It ignores the intervention of the Family Court into the marital affairs of the parties. It does not distinguish between fact, hearsay, inference or opinion. And it uses a form of terminology (Parental Alienation Syndrome) as though it were a recognised and commonly used psychiatric classification.
The Tribunal concluded at  that the psychologist had become the advocate for his client’s cause. There was little sign of an objective professional opinion. However the Tribunal revisited the duration of the conditions imposed.