[2019] EWCA Civ 74



Cliona Papazian
Michael Gration KC


Court of Appeal

Practice Areas

International Children Law

A judge’s finding that a wife had not been stranded in Pakistan was inconsistent with his finding that her husband had retained her passport. Stranding was a broad concept and could include any action taken by a spouse which put obstacles in the way of the other spouse being able to return to the UK. Even if that attempt was unsuccessful, it could still support a conclusion of controlling or coercive behaviour as referred to in CPR PD 12J.


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