ZA v YB (Appeal: Extending s91(14) Order: Unfair Procedure)

ZA v YB (Appeal: Extending s91(14) Order: Unfair Procedure)

The s91(14) order was made without procedural fairness, notice, or opportunity for the appellant to be heard, rendering the order unjust and requiring it to be set aside.

Parties
Appellant: ZA; Respondent: YB
Jurisdiction
England and Wales
Judgment Date
21 July 2025
Procedural Posture
Family Law Appeal / Appeal Judgment
Outcome
Appeal allowed; s91(14) order set aside; case remitted for reconsideration by a new judge.
Legal Topics
Section 91(14) Orders, Procedural Fairness, Children Act 1989, Appeals
Family Law Section 91(14) Orders Procedural Fairness Children Act 1989 Appeals

Case Brief

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Parties

ZA

Appellant

YB

Respondent

Procedural Posture

Family Law Appeal / Appeal Judgment

Legal Issues

  1. 1 Whether the extension of a s91(14) order was procedurally unfair
  2. 2 Whether the judge erred by making the order without notice or opportunity to be heard
  3. 3 Whether the duration of the order was arbitrary

Ratio Decidendi

The s91(14) order was made without procedural fairness, notice, or opportunity for the appellant to be heard, rendering the order unjust and requiring it to be set aside.

Court Disposition

Appeal allowed; s91(14) order set aside; case remitted for reconsideration by a new judge.

Orders

  • Case remitted to Family Court at Sussex – Brighton for reconsideration by a Circuit Judge other than HHJ Ahmed.
  • A temporary s91(14) order made until 30 November 2025, subject to discharge by the new judge.