
- The first section of this article deals with internal relocation. Both cases involve a mother who wished to relocate with the child.
- The second section deals with relocation to other jurisdictions, and include reference to R v Lucas, relating to findings of generalised dishonesty.
Child relocation cases remain difficult and often finely balanced. In this article we will summarise recent cases which have involved applications to relocate with children both within and outside of the jurisdiction.
Internal relocation
F v M [2023] EWFC 147
This concerned a girl, S, who was nearly four. Both parents applied for a child arrangements order, the father applied for a prohibited steps order, and the mother applied for a specific issue order seeking a proposed relocation from Borough A to Borough B (where the mother had already moved).
Within the section 7 report, Cafcass recommended the interim arrangements continue. However, the addendum report provided updated recommendations which supported a new