Is a threat of deportation 'Family Violence'?

Could threatening your intimate partner in the context of a spouse 820/801 be relevant to a claim of "Family Violence"?

Apart from being behaviour that is less than optimal it appears that such behaviour will be relevant to the opinion of the IE.

http://www8.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/FCCA/2019/1560.html