B, Re
There is a real and immediate risk to B of being forced into marriage, evidenced by the family’s culture of arranged and first cousin marriages, discussions about B’s betrothal, and M’s lack of candour and breach of court orders. A Forced Marriage Protection Order is necessary to protect B until she is 18. The evidence does not establish that F was forced to marry M, nor that either parent was subject to coercive or controlling behaviour during the marriage. Both parents have behaved poorly, but the threshold for further protective orders is not met.
- Parties
- Applicant: London Borough of Redbridge; Respondent/father: F; Respondent/mother: M; Subject Child: B (child, by Guardian AM)
- Jurisdiction
- England and Wales
- Judgment Date
- 19 November 2024
- Procedural Posture
- Family / Fact Finding Judgment
- Outcome
- Forced Marriage Protection Order granted; other applications dismissed; directions for further statements and analysis ordered.
- Legal Topics
- Forced Marriage Protection Order, Child Arrangements, Coercive and Controlling Behaviour, Cultural Practices in Marriage
Case Brief
Summary, issues, holding and outcome
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Parties
London Borough of Redbridge
Applicant
F
Respondent/father
M
Respondent/mother
B (child, by Guardian AM)
Subject Child
Procedural Posture
Family / Fact Finding Judgment
Legal Issues
- 1 Whether there is a culture and legacy of forced marriages in the family
- 2 Whether F was forced to marry M
- 3 Whether B has been betrothed to her cousin in Pakistan or the UK
Ratio Decidendi
There is a real and immediate risk to B of being forced into marriage, evidenced by the family’s culture of arranged and first cousin marriages, discussions about B’s betrothal, and M’s lack of candour and breach of court orders. A Forced Marriage Protection Order is necessary to protect B until she is 18. The evidence does not establish that F was forced to marry M, nor that either parent was subject to coercive or controlling behaviour during the marriage. Both parents have behaved poorly, but the threshold for further protective orders is not met.
Court Disposition
Forced Marriage Protection Order granted; other applications dismissed; directions for further statements and analysis ordered.
Orders
- A Forced Marriage Protection Order is made to protect B until she is 18 from being removed from the jurisdiction for the purpose of forced marriage.
- F’s application for an expert in forced marriages is dismissed.
Full Case Text
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