⌂ Tenant GuideTENANT / VICTORIA

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TIME / PUBLIC CASE RECORDS

Time: from an NTV to a possession order

Actual dates from published Victorian tenancy cases. Explore the distribution, compare cases and see how the days are counted.

In this public-case sample, 83.3% took at least 104 days.

5 of 6 dated records, measured from the earliest NTV recorded in the source to the initial possession decision. The observed range is 19–477 days.

See the 6 dated records ↓

5 judgments / PDFs + 1 digest · Sources checked 2026-11-11

01 / OBSERVED DAYS

The time distribution

Compare the records

Showing 6 records

Dated case records6
Shortest observed19days
Sample median121.5days
Longest observed477days

At least 80% of the selected records reached:104 days5/6 · 83.3%

  • 0–29 days
    1 / 6 · 16.7%
  • 30–59 days
    0 / 6 · 0%
  • 60–89 days
    0 / 6 · 0%
  • 90–119 days
    2 / 6 · 33.3%
  • 120–149 days
    1 / 6 · 16.7%
  • 150+ days
    2 / 6 · 33.3%

Days from the recorded NTV to the possession decision

02 / SOURCE DATES

The dates behind the numbers

Recorded NTV to initial PO / possession decision
Case / contextRecorded NTV dateInitial PO / possession decisionElapsed days
Smith v Director of Housing[2005] VSC 46 · Reproduced judgmentPublic housing · Danger · Historical caseService date recorded in the judgment19 days
Jafarpourasr v Tancevski[2018] VSC 497 · Reproduced judgmentPrivate rental · Family occupation · Historical caseRecorded service date; agent also described posting that day104 days
Liu v Tang[2022] VSC 243 · Reproduced judgmentPrivate rental · Arrears · COVID transition periodPosting date; not a verified service date108 days
Valenton v Shehata[2023] VCAT 11 · Tenants Victoria digestPrivate rental · Arrears · Digest evidenceSending date reported in the digest135 days
Lucas v Aparo[2025] VSC 138 · Reproduced judgmentPrivate rental · Possession ultimately based on saleEarliest NTV service date recorded in the judgment176 days
YPG v GMK[2026] VCAT 457 · Reproduced judgmentPrivate rental · Arrears · Adjournments and payment planFirst NTV expressly identified at paragraph 7477 days

Download case dates (CSV) ↓

03 / ACTUAL EVENTS

Case timelines and sources

Public housing · Danger · Historical case

Smith v Director of Housing [2005] VSC 46

19days
  1. NTV served
  2. PO application
  3. Hearing adjourned
  4. Possession granted

The 18 October hearing was adjourned; possession was granted on 26 October. The Court later found the NTV invalid. This measures the initial possession decision, not a final lawful eviction.

Source:Reproduced judgment ↗ · Reasons: factual passages dated 7, 18 and 26 October

Private rental · Family occupation · Historical case

Jafarpourasr v Tancevski [2018] VSC 497

104days
  1. Recorded NTV date
  2. NTV vacate date
  3. VCAT made the PO

The reasons record notice on 3 November and the PO on 15 February. The 1 March vacate date is not the endpoint. Some appeal grounds later succeeded.

Source:Reproduced judgment ↗ · Introduction and Background: 3 November notice and 15 February order

Private rental · Arrears · COVID transition period

Liu v Tang [2022] VSC 243

108days
  1. NTV posted
  2. NTV vacate date
  3. PO application
  4. VCAT made the PO

The notice was dated 8 July and posted on 9 July. The 3 August date was only the application. The PO followed on 25 October and was later set aside on appeal.

Source:Reproduced judgment ↗ · A. Introduction; B. The notice to vacate and amount ordered

Private rental · Arrears · Digest evidence

Valenton v Shehata [2023] VCAT 11

135days
  1. NTV sent (digest)
  2. PO application
  3. First PO

Tenants Victoria reports the first PO on 29 June. The second PO on 26 September and later review reasons are not the endpoint. Original reasons were not independently obtained.

Source:Tenants Victoria digest ↗ · Tenants Victoria 2026 digest §3.8, printed p.14 (filename says 2025)

Private rental · Possession ultimately based on sale

Lucas v Aparo [2025] VSC 138

176days
  1. Earliest recorded NTV
  2. Later sale NTV
  3. PO application
  4. VCAT made the PO

The February notice concerned bond and rent. The PO relied on the 2 April sale notice: 142 days from that later notice, which is not the earliest recorded NTV.

Source:Reproduced judgment ↗ · Introduction: 28 February, 2 April, 8 June and 22 August

Private rental · Arrears · Adjournments and payment plan

YPG v GMK [2026] VCAT 457

477days
  1. First NTV
  2. Second NTV; operative notice
  3. PO application
  4. Payment plan; no PO yet
  5. Final hearing
  6. VCAT made the PO

477 days from the first NTV; 463 from the operative second notice of 13 March. The 5 February hearing and 19 July vacate deadline are not the PO date.

Source:Reproduced judgment ↗ · Checked against the supplied PDF: paragraphs 7–16, 18–31, 96–109; order dated 19 June 2026

04 / COUNTING THE DAYS

How these figures were calculated

  1. Elapsed calendar days = initial PO / possession-decision date minus the recorded NTV date. The starting day is day 0; weekends and holidays count. No theoretical notice period is added.
  2. The sample comprises 5 judgments / PDFs and 1 Tenants Victoria digest, with notice dates from 2004–2025. These are the dated records checked for this page.
  3. Use the earliest NTV recorded in each source, including a superseded notice where recorded. Posting is labelled as posting. An explicitly identified first NTV is distinguished from other records where the source does not establish whether an earlier notice existed.
  4. The endpoint is the initial possession decision, including one later suspended or set aside. Application dates, later POs, vacate dates, warrants and actual evictions do not replace it.
  5. The sorted durations are 19, 104, 108, 135, 176, 477 days. 5 out of 6 (83.3%) reach 104 days; the median is 121.5 days. The 80% threshold is the largest observed duration reached by at least 80% of the selected records.

Date incomplete: not included in the distribution

Burnell v Executors of the Estate of Peter Athol Jenson [2024] VSC 505

An earlier NTV existed in 2023; the PO was made on 5 April 2024. The exact notice date is unknown, so no exact interval is included. The 45 days after the 20 February payment-plan order do not measure first NTV to PO.

Reproduced judgment ↗

Sources checked:

Use the time to prepare

Keep the NTV, rent ledger, evidence and hearing documents together. For an arrears notice or an existing PO, use the relevant guide.

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