AB v EM (Jurisdiction Foreign Custody Order), Re

AB v EM (Jurisdiction Foreign Custody Order), Re

M was habitually resident in England and Wales at the relevant dates; the English court has jurisdiction under the inherent jurisdiction based on habitual residence; England and Wales is the most appropriate forum; it is in M's best interests to be returned to England and Wales for welfare determination; the Lebanese custody order does not preclude this outcome.

Parties
Applicant: AB; Respondent: EM
Jurisdiction
England and Wales
Judgment Date
12 March 2020
Procedural Posture
Family / Final Judgment
Outcome
Application granted; summary return ordered.
Legal Topics
Habitual Residence, Jurisdiction, Forum Conveniens, Recognition of Foreign Orders, Child Welfare, Summary Return

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Parties

AB

Applicant

EM

Respondent

Procedural Posture

Family / Final Judgment

  1. 1 Was M habitually resident in England and Wales at the relevant dates?
  2. 2 Does the English court have jurisdiction under Art 8 or Art 10 of BIIa or parens patriae?
  3. 3 Is England and Wales the most convenient forum?

Ratio Decidendi

M was habitually resident in England and Wales at the relevant dates; the English court has jurisdiction under the inherent jurisdiction based on habitual residence; England and Wales is the most appropriate forum; it is in M's best interests to be returned to England and Wales for welfare determination; the Lebanese custody order does not preclude this outcome.

Court Disposition

Application granted; summary return ordered.

Orders

  • M to be returned from Egypt to England and Wales for welfare determination.
  • Tipstaff to retain father's travel documents until M is returned.