Re JXN (A Child) [2014] EWFC 17, [2014] All ER (D) 08 (Aug)
It was established law that applications for temporary removal to a non-convention country would involve consideration of three related elements: (a) the magnitude of the risk of breach of the order if permission was given; (b) the magnitude of the consequence of the breach if it occurred and; (c) the level of security that might be achieved by building in to the arrangements all of the available safeguards.