for the Gillick decision in "Marion's Case", Secretary of the Department of Health and Community Services v JWB and SMB (1992) 175 CLR 189. The Gillick competence doctrine is part of Australian case law (see, e.g., DoCS v Y [1999] NSWSC 644). There is no express authority in Australia on In re R and Re W, so whether a parent's right terminates is unclear. This lack of authority reflects that the reported cases have all involved minors who have been found to be incompetent, and that Australian courts will make decisions in the parens patriae jurisdiction regardless of Gillick competence. In South Australia and New South Wales legislation clarifies the common law, establishing a Gillick-esque standard of competence but preserving concurrent consent between parent and child for the ages 14–16. Confusion regarding Gillick competence On 21 May 2009, confusion arose between Gillick competence, which identifies under-16s with the capacity to consent to their own treatment, and the Fraser guidelines, which are concerned only with contraception and focus on the desirability of parental involvement and the risks of unprotected sex in that area. A persistent rumour arose that Victoria Gillick disliked having her name associated with the assessment of children's capacity, but an editorial in the BMJ from 2006 claimed that Gillick said that she "has never suggested to anyone, publicly or privately, that [she] disliked being associated with the term 'Gillick competent. Fraser guidelines It is lawful for doctors to provide contraceptive advice and treatment without parental consent providing certain criteria are met. These criteria, known as the Fraser guidelines, were laid down by Lord Fraser in the Gillick decision and require the professional to be satisfied that: the young person will understand the professional's advice; the young person cannot be persuaded to inform their parents; the young person is likely to begin, or to continue having, sexual intercourse with or without contraceptive treatment; unless the young person receives contraceptive treatment, their physical or mental health, or both, are likely to suffer; the young person's best interests require them to receive contraceptive advice or treatment with or without parental consent. Although these criteria specifically refer to contraception, the principles are deemed to apply to other treatments, including abortion. Although the judgment in the House of Lords referred specifically to doctors, it is considered by the Royal College of Obstetricians and Gynaecologists (RCOG) to apply to other health professionals, "including general