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Internal relocation: A new approach

Date:22 DEC 2015
Third slide
Barrister and Lecturer
Solicitor Advocate
Re C (Internal Relocation) [2015] EWCA Civ 1305 marks a new approach to internal relocation disputes. In this note Dr Rob George of Harcourt Chambers and James Netto of Dawson Cornwell who acted for the International Centre for Family Law Policy and Practice in intervening with ‘comprehensive submissions’ in the appeal (para [25]) consider the impact of this important new case.


From the earliest cases way back into the depths of time (1997 to be precise) internal relocation cases have been treated quite differently from their better-known relations the international relocation cases. Internal relocation cases involve a proposed move of a child within the UK while international cases are moves beyond that border.

The law developed two quite separate routes in relation to these different types of relocation decision though that has long been a subject of query and dissatisfaction. International relocation cases were considered using guidance developed over many years and culminating in Payne v Payne [2001] EWCA Civ 166 [2001] 1 FLR 1052 as interpreted following K v K (International Relocation: Shared Care...

Read the full article here.