W v L (Forum Conveniens)

W v L (Forum Conveniens)

M is habitually resident in England and Wales, giving the English court jurisdiction under Art 8(1) of BIIa. The father has not demonstrated that Jordan is a clearly and distinctly more appropriate forum. The English court is the natural and appropriate forum to determine the welfare issues concerning M.

Parties
Applicant: W; Respondent: L
Jurisdiction
England and Wales
Judgment Date
19 July 2019
Procedural Posture
Family / Interlocutory Judgment on Jurisdiction and Forum Conveniens
Outcome
Application granted; English court retains jurisdiction and will determine welfare issues.
Legal Topics
Habitual Residence, Jurisdiction, Forum Conveniens, Parental Responsibility, Child Welfare

Case Brief

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Parties

W

Applicant

L

Respondent

Procedural Posture

Family / Interlocutory Judgment on Jurisdiction and Forum Conveniens

  1. 1 Whether the child M is habitually resident in England and Wales
  2. 2 Whether the English court or the Jordanian court is the appropriate forum to determine welfare issues regarding M

Ratio Decidendi

M is habitually resident in England and Wales, giving the English court jurisdiction under Art 8(1) of BIIa. The father has not demonstrated that Jordan is a clearly and distinctly more appropriate forum. The English court is the natural and appropriate forum to determine the welfare issues concerning M.

Court Disposition

Application granted; English court retains jurisdiction and will determine welfare issues.

Orders

  • Declaration that M is habitually resident in England and Wales
  • Proceedings will not be stayed in favour of the Jordanian court