BY v GC [2025] EWFC 226 (24 July 2025)

BY v GC [2025] EWFC 226 (24 July 2025)

The application to admit further expert evidence was refused because the additional report was not necessary to assist the court to resolve the proceedings. The SJE's valuation suffices for the court's broad assessment of fairness, the difference in valuation, while significant, does not justify the disruption and delay that would result from admitting further expert evidence, and overall justice to both parties and the integrity of the timetable outweighs H's arguments for a second expert.

Citation
[2025] EWFC 226
Parties
Applicant: BY; Respondent: GC
Jurisdiction
England and Wales
Judgment Date
24 July 2025
Procedural Posture
Family Financial Remedies Application (daniels V Walker Application) / Interlocutory Application Prior to Final Hearing
Outcome
Application refused
Legal Topics
Expert Evidence, Financial Remedies, Single Joint Expert, Daniels V Walker Applications, Valuation of Business Assets
Family Law Expert Evidence Financial Remedies Single Joint Expert Daniels V Walker Applications Valuation of Business Assets

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Parties

BY

Applicant

GC

Respondent

Procedural Posture

Family Financial Remedies Application (daniels V Walker Application) / Interlocutory Application Prior to Final Hearing

Legal Issues

  1. 1 Whether the respondent (H) should be permitted to rely on expert evidence from FRP Advisory in addition to the single joint expert (PwC) in the context of disputed business valuations in financial remedy proceedings

Ratio Decidendi

The application to admit further expert evidence was refused because the additional report was not necessary to assist the court to resolve the proceedings. The SJE's valuation suffices for the court's broad assessment of fairness, the difference in valuation, while significant, does not justify the disruption and delay that would result from admitting further expert evidence, and overall justice to both parties and the integrity of the timetable outweighs H's arguments for a second expert.

Court Disposition

Application refused

Orders

  • H's application dated 1st July 2025 to rely on FRP Advisory report is refused.
  • Additional information provided to FRP Advisory to be sent to PwC (SJE) for consideration and response prior to final hearing.