(Family Division; Sumner J; 14 April 2008)
Following an abduction it was much harder for an abductor to claim that all was now well than when there was just a fear of abduction. It was common ground that if the father repeated his abduction and took the child to Tunisia the prospects of the mother successfully obtaining his return were remote, and the precautions had to be commensurate with that risk. However, it was over 4 years since the 9-day abduction, and the father had respected the mother's wishes and shown remarkable commitment to supervised contact for over 21 months. Unsupervised contact ought to proceed with sensible precautions; a scheme whereby the father could deposit and reclaim his passport would assist.