In a Decision – JR v BA (an "Unreported Decision") >> the Court Held:
The Appellate Division determined that other than when a Defendant cannot be served, there is no provision for an Indefinite Restraining Order.
The Appellate Division referenced to the Domestic Violence Procedures Manual. There is no provision in the Act that provides for the issuance of an "indefinite TRO." An "indefinite TRO" is regarded as one that has not been served upon a defendant named in a domestic violence complaint. This subsection states that when it is unlikely the defendant will be served within a reasonable period of time, the court can issue an indefinite TRO that continues the relief requested by the plaintiff and that a final hearing will be scheduled when the defendant is served. The police will not arrest a defendant if he or she violates an indefinite TRO, because the police will assume the defendant has not been served with the TRO. The court was not at liberty to enter what was in effect a final order, absent a finding or an admission defendant committed an act of domestic violence.