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England and Wales decisions
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FG v BN (Appeal Out of Time) [2026] EWFC 101 (B) (08 May 2026)
Appeal out of time in a financial remedies case dismissed. The court refused relief from sanctions after a 10½-month delay and upheld finality concerns.
Appeal out of time in a financial remedies case dismissed for serious delay, incomplete compliance, and no adequate explanation for the final months of default.
Awolowo v Awolowo [2026] EWFC 31 (16 February 2026)
Part III MFPA 1984 financial relief granted after an overseas divorce. The court ordered sale of the former matrimonial home and awarded the wife most of the net proceeds.
The Family Court made a Part III financial relief order after a Nigerian divorce, finding the husband had undisclosed assets and awarding the wife most of the former matrimonial home equity.
P (A Child) (Financial Provision: S 423 Insolvency Act 1986) [2025] EWHC 1460 (Fam) (04 June 2025)
The High Court made Schedule 1 financial provision for a child and found the father had concealed substantial wealth. Section 423 claims were adjourned.
The husband's deliberate non-disclosure and manipulation of the wife into exposure to substantial liabilities, combined with his abdication of financial responsibility and diversion of matrimonial assets, justify awarding the wife all UK properties and a clean break. The division ensures fairness, enables the wife to discharge liabilities, and reflects the husband's conduct and undisclosed assets.
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AP v RP [2025] EWFC 98 (B) (07 January 2025)
Financial remedies decision after marital breakdown and extensive non-disclosure, awarding the wife the UK properties to meet liabilities and provide a clean break.
Given the father's extensive non-disclosure, dishonesty, and evidence of substantial undisclosed assets, the court infers he can meet the mother's reasonable claims for C. The court awards a housing fund of £1,000,000, a commuted lump sum of £933,000 for maintenance and education, and £389,000 for debts and associated costs, with detailed arrangements for the use and reversion of the property and ring-fencing of funds. The commutation of maintenance is justified due to the father's history of non-compliance, litigation conduct, and enforcement difficulties.
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C (A Child) (Financial Provision: Non-disclosure), Re [2024] EWFC 115 (15 May 2024)
Schedule 1 Children Act claim over child C. The court found the father had concealed assets and made substantial provision for housing, maintenance, education and debts.
DH v RH [2024] EWFC 79 (18 April 2024)
Long-running financial remedy proceedings. The court rejected broad allegations of hidden assets, found late disclosure of Coinbase but no vast non-disclosure, and ordered an equalised division with an add-back for the wife's excessive legal costs.
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