S.O v A.B (Unapproved) [2024] IECA 110 (03 May 2024)

S.O v A.B (Unapproved) [2024] IECA 110 (03 May 2024)

The children were habitually resident in Germany at the time of removal; the mother failed to discharge the evidential burden to establish grave risk or intolerable situation under Article 13(b); allegations of bias and procedural unfairness were unsubstantiated; summary return is warranted, subject to protective undertakings by the father.

Citation
[2024] IECA 110
Parties
Respondent: S. O.; Appellant: A. B.
Jurisdiction
Ireland
Judgment Date
03 May 2024
Procedural Posture
Appeal / Judgment
Outcome
Appeal dismissed; High Court order affirmed.
Legal Topics
Hague Convention, Habitual Residence, Grave Risk Defence, Custody, Summary Return, Objective Bias

Case Brief

Summary, issues, holding and outcome

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Parties

S. O.

Respondent

A. B.

Appellant

Procedural Posture

Appeal / Judgment

  1. 1 Whether the children were habitually resident in Germany at the time of removal
  2. 2 Whether the defence of grave risk under Article 13(b) of the Hague Convention was established
  3. 3 Whether the trial judge was impartial

Ratio Decidendi

The children were habitually resident in Germany at the time of removal; the mother failed to discharge the evidential burden to establish grave risk or intolerable situation under Article 13(b); allegations of bias and procedural unfairness were unsubstantiated; summary return is warranted, subject to protective undertakings by the father.

Court Disposition

Appeal dismissed; High Court order affirmed.

Orders

  • Summary return of the two minor children to Germany forthwith
  • Protective undertakings to be provided by the father to facilitate return