C v B (Approved) [2026] IECA 21 (27 February 2026)

C v B (Approved) [2026] IECA 21 (27 February 2026)

The value of C's shareholding is relevant and necessary for the court's determination of proper provision in the divorce proceedings. The auditor's valuation is not binding on the court, and disclosure of the valuation report is required. Confidentiality concerns do not outweigh the necessity for disclosure, but can be addressed by limiting circulation to a confidentiality club of legal and professional advisers subject to undertakings.

Citation
[2026] IECA 21
Parties
Appellant: C; Respondent: B; Non Party: X Limited; Non Party: Z Limited
Jurisdiction
Ireland
Judgment Date
27 February 2026
Procedural Posture
Family Law Appeal / Court of Appeal Judgment on Non Party Discovery Order
Outcome
Appeal dismissed; High Court order varied
Legal Topics
Discovery, Confidentiality, Valuation of Assets, Proper Provision in Divorce, Non Party Disclosure
Family Law Civil Procedure Discovery Confidentiality Valuation of Assets Proper Provision in Divorce Non Party Disclosure

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Parties

C

Appellant

B

Respondent

X Limited

Non Party

Z Limited

Non Party

Procedural Posture

Family Law Appeal / Court of Appeal Judgment on Non Party Discovery Order

Legal Issues

  1. 1 Whether non-party discovery of a confidential valuation report should be ordered in divorce proceedings
  2. 2 Whether confidentiality concerns outweigh the necessity for disclosure to ensure proper provision
  3. 3 Whether the court is bound by an auditor's valuation under a nominee agreement

Ratio Decidendi

The value of C's shareholding is relevant and necessary for the court's determination of proper provision in the divorce proceedings. The auditor's valuation is not binding on the court, and disclosure of the valuation report is required. Confidentiality concerns do not outweigh the necessity for disclosure, but can be addressed by limiting circulation to a confidentiality club of legal and professional advisers subject to undertakings.

Court Disposition

Appeal dismissed; High Court order varied

Orders

  • Valuation report to be disclosed to a confidentiality club comprising named solicitors, counsel, and accountants/valuers, subject to undertakings of confidentiality and use solely for the proceedings.
  • Matter listed for mention to address outstanding issues including costs.