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England and Wales decisions
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The Father v The Mother & Anor [2026] EWHC 1012 (Fam) (30 April 2026)
The court refused an immediate return to Egypt for a child, holding return could only occur if an Egyptian consent order and financial safeguards were secured.
The balance of welfare factors tips decisively in favour of the mother's proposal for A to remain in Ghana with her, given the risks posed by the father's ongoing cannabis use, his lack of experience as sole carer, and the mother's willingness to comply with contact orders. The court finds the mother's plan to relocate genuine and considers that a mirror order in Ghana will safeguard A's relationship with her father. The disruption of moving A to England is outweighed by the risks of placing her in the father's care at this time.
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SA v TA (Relocation: Kingdom of Saudi Arabia) [2026] EWHC 756 (Fam) (08 February 2026)
The High Court refused the father’s application to relocate three children to Saudi Arabia, keeping them with their mother and making a s91(14) order.
The court refused the father’s application to relocate three children to Saudi Arabia, kept them living with their mother in the UK, and made a section 91(14) order.
The court found that the great aunt and uncle had failed to support N's relationship with her mother, leading to emotional harm and alienation. The original agreement was for N to return to her mother after her studies, and the mother is able to meet N's needs. Delay would entrench harm and make reunification more difficult. The paramount interests of N require an immediate transfer to her mother's care and relocation to Latvia, with indirect and then direct contact with the great aunt and uncle.
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Royal Borough of Windsor and Maidenhead v The Mother & Ors [2026] EWFC 16 (27 January 2026)
Care proceedings involving three children ended with no care order, a child arrangements order for them to live with their mother in Sweden, removal of the father’s parental responsibility, and a non-molestation order.
The court found extensive domestic abuse by F against M and the children, determined that the children should live with M with only indirect contact with F pending completion of domestic abuse and anger management programmes, and concluded that international relocation could not be granted at this stage but permission to travel was appropriate, with relocation application adjourned for further consideration.
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M v F (Domestic Abuse: International Relocation) [2025] EWFC 360 (15 October 2025)
The court made further findings of serious domestic abuse, ordered the children to live with their mother, kept indirect contact with the father, and imposed intervention requirements before direct contact.
O (Domestic Abuse: International Relocation) [2025] EWCA Civ 888 (14 July 2025)
The Court of Appeal dismissed a father’s appeal against permission for the mother to relocate two children to the UAE, holding the welfare analysis and proportionality assessment were sound.
It is in the child's best interests for the mother to be permitted to relocate with him to Dubai, given the enhanced quality of life, education, and stability provided, and the minimal current impact on the child's relationship with the father, which is limited to indirect contact. The father's application for summary return is refused as the welfare analysis does not support return. Progression to direct contact is premature due to unresolved risks from domestic abuse and insufficient evidence of meaningful change by the father. The application for variation of the child arrangements order i…
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