Bokor-Ingram v Bokor-Ingram

Bokor-Ingram v Bokor-Ingram

The husband's failure to disclose the imminent likelihood of a new, higher-paying contract constituted a breach of the duty of disclosure, and had proper disclosure been made, the consent order would not have been made in its existing form. The judge below erred in concluding the breach had no effect on the outcome.

Parties
Appellant: Bokor-Ingram; Respondent: Bokor-Ingram
Jurisdiction
England and Wales
Judgment Date
04 March 2009
Procedural Posture
Family Law Ancillary Relief / Appeal From Dismissal of Application to Set Aside Consent Order
Outcome
Appeal allowed; application granted
Legal Topics
Ancillary Relief, Duty of Disclosure, Setting Aside Consent Orders
Family Law Ancillary Relief Duty of Disclosure Setting Aside Consent Orders

Case Brief

Summary, issues, holding and outcome

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Parties

Bokor-Ingram

Appellant

Bokor-Ingram

Respondent

Procedural Posture

Family Law Ancillary Relief / Appeal From Dismissal of Application to Set Aside Consent Order

Legal Issues

  1. 1 Whether the husband's failure to disclose imminent higher remuneration justified setting aside the consent order
  2. 2 Whether the judge below applied the correct test for disclosure in ancillary relief proceedings

Ratio Decidendi

The husband's failure to disclose the imminent likelihood of a new, higher-paying contract constituted a breach of the duty of disclosure, and had proper disclosure been made, the consent order would not have been made in its existing form. The judge below erred in concluding the breach had no effect on the outcome.

Court Disposition

Appeal allowed; application granted

Orders

  • Consent order of 20 July 2006 set aside
  • Revised orders to be made on the wife's applications