The Court of Appeal has issued a judgment which provides guidance on the appropriate criteria for extensions of compulsory care orders under section 85 of the Intellectual Disability (Compulsory Care and Rehabilitation) Act 2003. In particular, the Court of Appeal found that extension orders sometimes require an increased justification compared to initial orders, noting that as the length of an order increased the weight that should be given to the subject's liberty interests also increased. The Court of Appeal also found that the nature of the original offending was relevant to the extension decision, both as an indicator of possible risk and, in more finely balanced cases, as a consideration as to whether an extension would be out of proportion with the original offending. RIDCA Central v VM [2011] NZCA 659.