Family Law · The Court of Appeal of England and Wales (Civil Division)
S-O (Children) (Relocation and Prohibited Steps Order), Re
Facts
The appellant mother had two children: S, a boy of 14, whose father (F1) she separated from in 2012, and C, a girl of 6, whose father (F2) she married in 2018 and separated from in June/July 2025. The family had always lived in London, but in December 2023 the mother was posted to the Middle East, commuting between there and London while the children remained at the family home with F2 and a long-term nanny; from mid-2025 she was based in a Gulf State ("State A"), spending roughly twenty days a month there. F1 applied in January 2025 for a child arrangements order and, in July 2025, for a prohibited steps order preventing S's removal from the jurisdiction; the mother applied on 10 July 2025 to relocate both children to State A, alleging domestic abuse by F2 and seeking a non-molestation order under the Family Law Act 1996. A prohibited steps order was made by Her Honour Judge Burne on 6 August 2025. An independent social worker recommended that S remain in England but that C relocate; the mother then pursued relocation for C alone. After a four-day hearing, Her Honour Judge Major, sitting as a Deputy High Court Judge, dismissed the relocation application and continued the prohibited steps order on 27 February 2026. The mother appealed on four grounds.
What did the court decide?
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