LA v M & Ors [2025] EWHC 630 (Fam) (18 February 2025)

LA v M & Ors [2025] EWHC 630 (Fam) (18 February 2025)

Given the established facts of forced marriage, parents' dishonesty, and ongoing high risk, the court finds that the extension of FMPOs and Passport Orders until the young people are 21 is necessary and proportionate to protect them from serious harm, outweighing the intrusion into Article 8 rights.

Citation
[2025] EWHC 630 (Fam)
Parties
Applicant: LA; First Respondent: M; Second Respondent: F; Third Respondent: X; Fourth Respondent: Y; Fifth Respondent: Z
Jurisdiction
England and Wales
Judgment Date
18 February 2025
Procedural Posture
Family Law Forced Marriage Protection Order / Judgment on Extension of Fmpos and Passport Orders
Outcome
FMPOs and Passport Orders extended until the young people reach 21 years of age.
Legal Topics
Forced Marriage Protection Orders, Passport Orders, Article 3 ECHR, Article 8 ECHR, Autonomy of Young Adults, Proportionality Assessment
Family Law Human Rights Forced Marriage Protection Orders Passport Orders Article 3 ECHR Article 8 ECHR Autonomy of Young Adults Proportionality Assessment

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Parties

LA

Applicant

M

First Respondent

F

Second Respondent

X

Third Respondent

Y

Fourth Respondent

Z

Fifth Respondent

Procedural Posture

Family Law Forced Marriage Protection Order / Judgment on Extension of Fmpos and Passport Orders

Legal Issues

  1. 1 Whether Forced Marriage Protection Orders (FMPOs) should be extended until the young people are 21 years old
  2. 2 Whether Passport Orders in respect of the parents should be extended until Z's 21st birthday
  3. 3 Balancing Article 3 and Article 8 ECHR rights in the context of forced marriage risk

Ratio Decidendi

Given the established facts of forced marriage, parents' dishonesty, and ongoing high risk, the court finds that the extension of FMPOs and Passport Orders until the young people are 21 is necessary and proportionate to protect them from serious harm, outweighing the intrusion into Article 8 rights.

Court Disposition

FMPOs and Passport Orders extended until the young people reach 21 years of age.

Orders

  • Forced Marriage Protection Orders in respect of X, Y, and Z extended to their 21st birthdays.
  • Passport Orders in respect of both parents extended to Z's 21st birthday.