The order has put a major roadblock in Ezekiel-Hart’s long-running revenge campaign against the ACT Law Society and former president Robert Reis, which began after the council refused to issue him with an unrestricted practising certificate in September 2008.

Ezekiel-Hart has attempted to overturn this in the ACT Supreme Court, Court of Appeal, the High Court, the ACT Civil and Administrative Tribunal, and the then-Federal Circuit Court. He also initiated criminal proceedings in the ACT Magistrates Court.

Each of the proceedings repeated much of the same allegations that Ezekiel-Hart had been subjected to unlawful discrimination on the grounds of his race, had received unfavourable treatment, and was targeted as a way to “harm my human rights and kill me”.

While it was not necessary to do so to make the order, Justice Needham echoed the findings of many other judges before her in determining that the evidence against Reis and the Law Society, taken at its highest, does not come close to establishing malice.

Justice Needham also noted the litigation has meant resources have been taken from the ACT Law Society, which has “regulatory and policy obligations owed to members … and the public”.

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“It is also relevant that the submissions, evidence, and arguments of the applicant are often inflammatory and overstated; those persons who are officials of the council or its employees should not have to deal with such serious allegations where those allegations have little or no basis in fact,” Justice Needham said.

“It is problematic, to say the least, that allegations of the kind detailed above have been made by an experienced legal practitioner in the context of seeking to practise pursuant to a grant of an unrestricted practising certificate.”

During the vexatious proceedings hearing in March, Ezekiel-Hart alleged Reis lied about his fitness to practice after the two met and argued during a 2008 practice management course.

Nicholas Olson, appearing for the Law Society, said the vexatious order would protect the public from Ezekiel-Hart’s ongoing use of the court’s resources.”

“The originating application and statement of claim … remain focused on the historical matters relating to his practising certificate, and they also reveal that Chief Ezekiel-Hart continues to make serious allegations that are tantamount to fraud or dishonesty,” he said.

“I submit it is a continuation of previous conduct and an indicator of what future conduct may be if vexatious orders are not made.”

Justice Needham determined that given Ezekiel-Hart’s history of relitigation and him having commenced similar proceedings in different courts and jurisdictions, “that he would, if not restrained by a vexatious proceeding order, continue to seek to initiate or conduct vexatious proceedings in this court”.

Ezekiel-Hart’s originating application has been dismissed, and the Law Society has been granted leave to apply for special costs order.

The case: Ezekiel-Hart v Council of the Law Society of the ACT (Vexatious Proceedings Order) [2025] FCA 551 (2 June 2025)