Partner Renato Labi, Senior Associate Liam Bennett and Trainee Solicitor Surya Dawar, instructing William Tyler KC and Meredith Major of The 36 Group, successfully represented the appellant father in an appeal concerning child arrangements and international relocation.

The Court of Appeal allowed the appeal, holding that observations made in earlier summary Hague Convention proceedings had wrongly been treated as findings of fact in the subsequent Children Act proceedings. The Court concluded that those observations “had no status in the Children Act proceedings and should have attracted no weight in the judge’s assessment of the issues”. The decision and findings were set aside, and the Children Act applications were remitted for a complete rehearing before another judge of the Family Division.

The judgment clarifies the status and treatment of judicial observations made in summary child abduction proceedings when the court subsequently determines welfare issues under the Children Act 1989.

The case has been reported X and Y (Child Arrangements: Findings), Re [2026] EWCA Civ 1169.

The published judgment can be found here.