L v D [2004] JLR 334 (14 September 2004)

L v D [2004] JLR 334 (14 September 2004)

A cohabitee's contribution to family living costs is a material change in circumstances that may justify reducing child maintenance, but voluntary contributions to the child's maintenance by the cohabitee are irrelevant.

Citation
[2004] JLR 334
Parties
Applicant: L; Respondent: D
Jurisdiction
Jersey
Judgment Date
14 September 2004
Procedural Posture
Family Law Variation of Maintenance / Judgment
Outcome
child maintenance reduced
Legal Topics
Financial Provision, Child Maintenance, Variation of Maintenance, Cohabitation
Family Law Financial Provision Child Maintenance Variation of Maintenance Cohabitation

Case Brief

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Parties

L

Applicant

D

Respondent

Procedural Posture

Family Law Variation of Maintenance / Judgment

Legal Issues

  1. 1 Whether cohabitation of custodial parent and contribution to family living costs by cohabitee constitutes a material change in circumstances justifying reduction in child maintenance
  2. 2 Whether voluntary contributions to child's maintenance by cohabitee are relevant

Ratio Decidendi

A cohabitee's contribution to family living costs is a material change in circumstances that may justify reducing child maintenance, but voluntary contributions to the child's maintenance by the cohabitee are irrelevant.

Court Disposition

child maintenance reduced

Orders

  • child maintenance payments reduced due to cohabitee's contribution to family living costs