A McKenzie Friend (MF) is someone who assists an unrepresented person in court. They can be a lawyer, but they are not a substitute for a lawyer. So lawyer or not, when acting as a MF they may not address the court; they can take notes, organise papers, whisper quietly to and generally assist the litigant. McKenzie v McKenzie (1970) 3 W.L.R 472 was a family law case and MFs are more common in family and guardianship matters, but they may be permitted in any court where an unrepresented person needs assistance to ensure fairness. However, some MFs are overbearing do-gooders, or bush lawyers, who cause disruption and delay rather than actually assist and will not be permitted to remain. In guardianship hearings where there is no right of representation, a lawyer can act as a MF.