Schofield v Schofield [2011] EWCA Civ 174 (02 February 2011)

Schofield v Schofield [2011] EWCA Civ 174 (02 February 2011)

The judge below applied an incorrect threshold for granting leave, requiring a probability assessment of 50% rather than substantial ground. The army pension is significant in context, and public policy requires English courts to cooperate in providing relief where foreign courts lack jurisdiction over English assets. The appeal is allowed and leave should be granted.

Citation
[2011] EWCA Civ 174
Parties
Appellant: Schofield; Respondent: Schofield
Jurisdiction
England and Wales
Judgment Date
02 February 2011
Procedural Posture
Appeal / Judgment
Outcome
appeal allowed
Legal Topics
Pension Sharing, Financial Relief After Foreign Divorce, Jurisdictional Cooperation

Case Brief

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Parties

Schofield

Appellant

Schofield

Respondent

Procedural Posture

Appeal / Judgment

  1. 1 Whether English courts should grant leave for financial relief application after foreign divorce when foreign court lacks jurisdiction over English pension assets
  2. 2 Appropriate threshold for granting leave under Part 3 Matrimonial and Family Proceedings Act 1984

Ratio Decidendi

The judge below applied an incorrect threshold for granting leave, requiring a probability assessment of 50% rather than substantial ground. The army pension is significant in context, and public policy requires English courts to cooperate in providing relief where foreign courts lack jurisdiction over English assets. The appeal is allowed and leave should be granted.

Court Disposition

appeal allowed

Orders

  • Appeal allowed
  • Fresh evidence admitted