AG and AB (Children)

AG and AB (Children)

The children were not habitually resident in England and Wales at the relevant date; the judge applied the correct legal principles and was entitled to find habitual residence in Canada. The court had residual jurisdiction under the Family Law Act 1986, but the discharge of the prohibited steps order was correct given the circumstances and ongoing proceedings in Canada.

Parties
Appellant: FA; Respondent: JR
Jurisdiction
England and Wales
Judgment Date
28 February 2018
Procedural Posture
Appeal / Judgment
Outcome
Appeal dismissed
Legal Topics
Habitual Residence, Jurisdiction, Child Arrangements, Prohibited Steps Order, Brussels IIA, Family Law Act 1986, Children Act 1989

Case Brief

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Parties

FA

Appellant

JR

Respondent

Procedural Posture

Appeal / Judgment

  1. 1 Whether the children were habitually resident in England and Wales at the relevant date
  2. 2 Whether the English court had jurisdiction to determine the father's application under the Children Act 1989
  3. 3 Interpretation of Article 13 of Brussels IIA and s.2(1)(b) of the Family Law Act 1986

Ratio Decidendi

The children were not habitually resident in England and Wales at the relevant date; the judge applied the correct legal principles and was entitled to find habitual residence in Canada. The court had residual jurisdiction under the Family Law Act 1986, but the discharge of the prohibited steps order was correct given the circumstances and ongoing proceedings in Canada.

Court Disposition

Appeal dismissed

Orders

  • Discharge of prohibited steps order upheld
  • No substantive order made under s.8 of the Children Act 1989