F v M

F v M

The Article 13(b) defence was made out due to the severe and genuine impact of M's mental health, lack of immigration status, and absence of adequate protective measures, which would render X's return intolerable. Habitual residence had transferred to New Zealand, and X's objections did not meet the threshold required by the Convention.

Parties
Applicant: F; Respondent: M
Jurisdiction
England and Wales
Judgment Date
23 July 2024
Procedural Posture
Hague Convention Child Abduction Application / Final Judgment
Outcome
Application for return order dismissed
Legal Topics
Habitual Residence, Child's Objections, Article 13(b) Defence, Protective Measures, Mental Health Impact

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Parties

F

Applicant

M

Respondent

Procedural Posture

Hague Convention Child Abduction Application / Final Judgment

  1. 1 Was the child X habitually resident in New Zealand at the time of removal?
  2. 2 Does X object to being returned to New Zealand within the meaning of the Hague Convention?
  3. 3 Is there a grave risk that return would expose X to physical or psychological harm or place him in an intolerable situation under Article 13(b)?

Ratio Decidendi

The Article 13(b) defence was made out due to the severe and genuine impact of M's mental health, lack of immigration status, and absence of adequate protective measures, which would render X's return intolerable. Habitual residence had transferred to New Zealand, and X's objections did not meet the threshold required by the Convention.

Court Disposition

Application for return order dismissed

Orders

  • No return order is made under the Hague Convention
  • X remains in England with M