Brough v Law & Anor [2011] EWCA Civ 1183 (20 October 2011)

Brough v Law & Anor [2011] EWCA Civ 1183 (20 October 2011)

A brief period of parents living together does not terminate a maintenance assessment under paragraph 16(1)(b); the provision is concerned with permanent loss of qualifying child status, not temporary changes. Paragraph 16(1)(d) governs termination upon six months' continuous cohabitation.

Citation
[2011] EWCA Civ 1183
Parties
Appellant: Michael Brough; First Respondent: Sharon Law; Second Respondent: Child Maintenance and Enforcement Commission
Jurisdiction
England and Wales
Judgment Date
20 October 2011
Procedural Posture
Appeal / Court of Appeal Judgment
Outcome
Appeal dismissed
Legal Topics
Child Support, Maintenance Assessment, Statutory Interpretation

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 7 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

Michael Brough

Appellant

Sharon Law

First Respondent

Child Maintenance and Enforcement Commission

Second Respondent

Procedural Posture

Appeal / Court of Appeal Judgment

  1. 1 Whether a brief period of reconciliation between parents terminates a maintenance assessment under paragraph 16(1)(b) of Schedule 1 to the Child Support Act 1991
  2. 2 Interpretation of 'qualifying child' and 'absent parent' under the Act

Ratio Decidendi

A brief period of parents living together does not terminate a maintenance assessment under paragraph 16(1)(b); the provision is concerned with permanent loss of qualifying child status, not temporary changes. Paragraph 16(1)(d) governs termination upon six months' continuous cohabitation.

Court Disposition

Appeal dismissed

Orders

  • Maintenance assessment remains valid; no automatic termination from brief reconciliation