TYB v CAR (Non-Disclosure) (No 2) [2025] EWFC 263 (30 June 2025)

TYB v CAR (Non-Disclosure) (No 2) [2025] EWFC 263 (30 June 2025)

The respondent husband's persistent and deliberate non-disclosure, despite multiple opportunities and court orders, entitles the court to presume his financial circumstances remain as previously known, justifying the maintenance and costs orders sought by the applicant wife. The court is not satisfied there has been any material change in his finances and finds his assertions of reduced income to be dishonest and unsupported.

Citation
[2025] EWFC 263
Parties
Applicant Wife: TYB; Respondent Husband: CAR
Jurisdiction
England and Wales
Judgment Date
30 June 2025
Procedural Posture
Financial Remedies on Divorce / Final Judgment After Repeated Non Disclosure and Adjournments
Outcome
Applicant wife's claims for maintenance and costs allowed; capital claims adjourned for up to 10 years; respondent husband ordered to pay maintenance, arrears, indemnities, and costs.
Legal Topics
Financial Remedies, Non Disclosure, Adverse Inference, Spousal Maintenance, Child Maintenance, Costs Orders
Family Law Financial Remedies Non Disclosure Adverse Inference Spousal Maintenance Child Maintenance Costs Orders

Case Brief

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Parties

TYB

Applicant Wife

CAR

Respondent Husband

Procedural Posture

Financial Remedies on Divorce / Final Judgment After Repeated Non Disclosure and Adjournments

Legal Issues

  1. 1 Whether the respondent husband has suffered a material change in financial circumstances justifying reduced financial provision
  2. 2 Whether the court should draw adverse inferences from the husband's persistent non-disclosure
  3. 3 What level of spousal and child maintenance is appropriate given the evidence and non-disclosure

Ratio Decidendi

The respondent husband's persistent and deliberate non-disclosure, despite multiple opportunities and court orders, entitles the court to presume his financial circumstances remain as previously known, justifying the maintenance and costs orders sought by the applicant wife. The court is not satisfied there has been any material change in his finances and finds his assertions of reduced income to be dishonest and unsupported.

Court Disposition

Applicant wife's claims for maintenance and costs allowed; capital claims adjourned for up to 10 years; respondent husband ordered to pay maintenance, arrears, indemnities, and costs.

Orders

  • Respondent husband to pay spousal maintenance of £5,500 per month in advance from 1 August 2025, with credit for any future child support payments made through the agency.
  • Respondent husband to pay arrears of spousal maintenance of £11,000 by end of September 2025.