LA v M & Ors

LA v M & Ors

Given the proven risk of forced marriage, past parental dishonesty, and lack of protective factors, the extension of FMPOs and Passport Orders until the young people’s 21st birthdays is necessary and proportionate to protect them from harm, outweighing the intrusion into Article 8 rights.

Parties
Applicant: LA; First Respondent: M; Second Respondent: F; Third Respondent: X; Fourth Respondent: Y; Fifth Respondent: Z
Jurisdiction
England and Wales
Judgment Date
17 March 2025
Procedural Posture
Family Law / Judgment on Extension of Forced Marriage Protection Orders and Passport Orders
Outcome
FMPOs and Passport Orders extended until the young people’s 21st birthdays.
Legal Topics
Forced Marriage Protection Orders, Passport Orders, Article 3 ECHR, Article 8 ECHR, Autonomy of Young Adults, Arranged Vs Forced Marriage
Family Law Human Rights Forced Marriage Protection Orders Passport Orders Article 3 ECHR Article 8 ECHR Autonomy of Young Adults Arranged Vs Forced Marriage

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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 / Judgment on Extension of Forced Marriage Protection Orders and Passport Orders

Legal Issues

  1. 1 Should Forced Marriage Protection Orders (FMPOs) be extended until the young people’s 21st birthdays?
  2. 2 Should Passport Orders in respect of the parents be extended until Z’s 21st birthday?

Ratio Decidendi

Given the proven risk of forced marriage, past parental dishonesty, and lack of protective factors, the extension of FMPOs and Passport Orders until the young people’s 21st birthdays is necessary and proportionate to protect them from harm, outweighing the intrusion into Article 8 rights.

Court Disposition

FMPOs and Passport Orders extended until the young people’s 21st birthdays.

Orders

  • Forced Marriage Protection Orders extended until X, Y, and Z reach 21 years of age.
  • Passport Orders in respect of both parents extended until Z’s 21st birthday (six more years).