Since "ABC v Lenah Game Meats", the question of whether invasion of privacy is a valid cause of action has been entertained in at least two states. The most adventurous decision is arguably that of the District Court of Queensland in "Grosse v Purvis", in which Judge Skoien awarded damages for invasion of privacy. Conversely, the existence of the tort was questioned by Justice Gillard of the Supreme Court of Victoria in "Giller v Procopets", in which the Court held the law had 'not developed to the point where the law in Australia recognises an action for breach of privacy'