H (Abduction: Retention In Non-Contracting State), Re

H (Abduction: Retention In Non-Contracting State), Re

A wrongful retention that occurred in a non-Contracting State is justiciable under the Hague Convention in a Contracting State, provided the child was habitually resident in a Contracting State at the time of the retention and the application is determined in a Contracting State. The Convention does not require the retention to have occurred in a Contracting State.

Parties
Appellant: Mother; Respondent: Father
Jurisdiction
England and Wales
Judgment Date
16 April 2019
Procedural Posture
Family Law Child Abduction (hague Convention) / Appeal From High Court to Court of Appeal
Outcome
Appeal dismissed
Legal Topics
Child Abduction, Hague Convention 1980, Wrongful Retention, Jurisdiction

Case Brief

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Parties

Mother

Appellant

Father

Respondent

Procedural Posture

Family Law Child Abduction (hague Convention) / Appeal From High Court to Court of Appeal

  1. 1 Does the Hague Convention apply when the act of wrongful retention occurred in a non-Contracting State?
  2. 2 Can a wrongful retention that occurred in a non-Contracting State be justiciable in a Contracting State under the Convention?

Ratio Decidendi

A wrongful retention that occurred in a non-Contracting State is justiciable under the Hague Convention in a Contracting State, provided the child was habitually resident in a Contracting State at the time of the retention and the application is determined in a Contracting State. The Convention does not require the retention to have occurred in a Contracting State.

Court Disposition

Appeal dismissed

Orders

  • Order of Mostyn J for the return of the child to Australia upheld