The Summary of the Summaries (Spring 2026)

AT v NB (No 2) (Maintenance Pending Suit: Costs) [2025] EWFC 287 (B) (DDJ Mark Harrop)

Judgment regarding costs arising out of an application for maintenance pending suit. W awarded 50% of her costs as whilst W’s claim was reasonable and manifestly required, W was unlikely to ever receive the quantum sought which she had maintained throughout. Keywords: maintenance pending suit; costs

Re H (A Child) (Appeal: Child Maintenance) [2025] EWHC 2361 (Fam) (Henke J)

Failed appeal by the father against the extension of the duration of a child maintenance order beyond the age of 18. Keywords: child maintenance

G v N [2025] EWFC 286 (B) (District Judge Shackleton)

Application for a financial remedy order following divorce between a husband and wife, following a 30-year separation. The order sought, and granted, was for the matrimonial home be transferred into the husband’s sole name. Keywords: financial remedies

KU v BI [2025] EWFC 296 (B) (Deputy District Judge Williams)

Final hearing concerning the validity of a foreign customary marriage (Nigerian) and whether financial remedy proceedings could be pursued. The court found there had been a valid marriage, distinguishing authorities relied upon by the single joint expert. Keywords: nullity; non-qualifying ceremony; lex loci celebrations

Hampshire v Bonser [2025] EWCC 55 (HHJ Owen)

Claim for a declaration of beneficial interest in the net sale proceeds of a bed and breakfast come former family home. Keywords: TLATA claims; trusts; cohabitation; detrimental reliance; common intention; non-financial contributions

Collardeau v Fuchs [2025] EWFC 307 (Poole J)

Enforcement and variation: the court quantified arrears, discharged and capitalised the respondent husband’s mortgage undertaking, replaced multiple undertakings with quantified periodical payments, and ordered immediate enforcement where H frustrated a sealed final financial remedy order. Keywords: Duxbury capitalisation; enforcement; variation applications; release from undertakings; periodical payments

HA v EN [2025] EWHC 2436 (Fam) (The Hon Richard Todd KC, sitting as a deputy High Court Judge)

Court varied Xydhias agreement, imposing significant contingent reduction in maintenance following change in circumstances. Keywords: agreements; Xydhias; pre-nuptial agreements; variation; maintenance

K v P (Criminal Solicitor as Court-Appointed QLR) [2025] EWFC 321 (Sir Andrew McFarlane, President of the Family Division)

Court-appointed qualified legal representative (QLR) was discharged in children proceedings where the same QLR was acting in a parallel criminal case, as the dual representation undermines the protective aims of the Domestic Abuse Act 2021 scheme for vulnerable witnesses. Keywords: qualified legal representative; domestic abuse

Armstrong v Armstrong & Anor (Re Remedy) [2025] EWHC 2054 (Ch) (Andrew Sutcliffe KC, sitting as a High Court Judge)

Judgment considering the appropriate remedy for a claimant who had proved his proprietary estoppel claim and his alternative claim for entitlement under the Inheritance (Provision for Family and Dependants) Act 1975. Keywords: Inheritance Act applications; farms and country estates; proprietary estoppel

FO v PN [2025] EWFC 327 (B) (HHJ Hess)

HHJ Hess explored the weight which should be given to pre-nuptial agreements and Deeds of Revocations where the Deed of Revocation is entered into shortly before the demise of a marriage. Deed of Revocation held to be a ‘magnetic factor’, the judge rejecting the husband’s attack against it. Keywords: agreements; pre-nuptial agreements; deeds of revocation

Sandra Ozturk v Yilmaz Ozturk [2025] EWFC 333 (B) (HHJ Moreton)

Suspended committal activated: 28 days’ immediate imprisonment for wilful breach of a Form E disclosure order in financial remedy proceedings. Keywords: committal applications and judgment summonses; disclosure

TX v YA (No 2) [2025] EWFC 349 (Cusworth J)

Wife’s successful application for financial relief after the parties’ divorce in Germany, where there is a Deed outlining agreed financial provision, the court concluding the German Deed was inadequate to meet the needs of the wife given the change in circumstances. Keywords: Part III; Maintenance Regulation (EU)

TY v XA (No 3) [2025] EWFC 350 (Cusworth J)

Wife was granted a costs order for her ‘disproportionate’ legal costs on the standard basis due to husband’s ‘normal’ litigation misconduct. Keywords: costs; Part III

A v N [2025] EWFC 371 (B) (Recorder Christopher Stirling)

Final hearing in financial remedy proceedings involving an intervener claim from W’s elderly mother. Guidance given as to how the representations of third parties should be balanced against the needs of the spouses in accordance with s 24A(6) MCA 1973. Keywords: joinder of third parties; housing need

OO v QQ [2025] EWFC 310 (B) (HHJ Hyde KC)

Final hearing in financial remedy proceedings. The husband had failed to engage with most of the process. The case was determined on a needs basis given the wife’s terminal cancer diagnosis. Keywords: trusts; needs; life expectancy; terminal illness

NI v AD [2025] EWHC 2997 (Fam) (Trowell J)

Wife (NI) and husband (AD) cohabited for 7 years and share three children, aged, 11, 9 and 8. This is a cross application for financial relief upon their divorce. Oral evidence was heard from husband, wife and two expert forensic accountants. Keywords: companies; company valuations; spousal maintenance (quantum)

MH v FD [2025] EWFC 390 (Justin Warshaw KC, sitting as a deputy High Court Judge)

Application for interim relief within proceedings brought under Sch 1 Children Act 1989. The father took the ‘millionaire’s defence’. The court determined the father should pay towards unpaid and future legal costs in both the Sch 1 and CA 1989 proceedings. Keywords: Children Act 1989, Schedule 1 applications; interim relief; millionaire’s defence

ED v AP [2025] EWFC 399 (HHJ Hess, sitting as deputy High Court Judge)

Final hearing in financial remedy proceedings. The judge dealt with how to formulate a fair Wells sharing order concerning contingent interests the husband might receive as a result of his work. Keywords: Wells sharing

Collardeau v Fuchs: Contempt of Court [2025] EWFC 413 (Poole J)

Application for committal to prison for contempt of court following alleged breaches of an order made varying a final financial order. Finding the husband guilty of contempt, sentencing was adjourned to allow the husband time to prepare his mitigation in circumstances where he had paid $41m ahead of the contempt hearing, substantially meeting his obligations under the order. Keywords: enforcement (international); contempt of court; committal applications and judgment summonses; service

ABC v XYZ (Financial Remedies: Release from Undertakings and Variation of Periodical Payments Order) [2025] EWFC 370 (B) (DJ Maddison)

Application by H to be released from undertakings and vary a nominal maintenance order following a significant change of circumstances. Reassessment of needs resulted in substantive joint lives provision. Keywords: periodical payments; variation applications; undertakings

Silberschmidt v Richards [2025] EWHC 2841 (Fam) (Poole J)

Husband’s appeal against setting aside of final consent order for fraudulent non-disclosure dismissed; wife’s delay not determinative. Keywords: delay; setting aside orders (including Barder applications); fraud; non-disclosure

MRU v ECR (Financial Remedies) [2025] EWFC 218 (B) (Deputy District Judge Rose)

Final hearing in financial remedy proceedings. The judge dealt with issues of conduct, cost orders and transparency. The judge found W’s conviction in the Crown Court was ‘gross and obvious personal misconduct’ which had a ‘financial consequence’ in accordance with Mostyn J’s decision in OG v AG [2020] EWFC 52. Keywords: conduct; transparency; needs

RKV v JWC (No 2) [2025] EWFC 429 (B) (Recorder Rhys Taylor)

Wife was granted a costs order for legal costs on the indemnity basis due to the husband’s ‘complete and multi-faceted’ misconduct, namely deception and refusal to comply with court orders. Keywords: costs

VP v SP [2025] EWFC 447 (B) (Deputy District Judge Cassidy Hope)

Judgment in financial remedy proceedings addressing needs-based distribution where one party is the primary carer of a disabled adult child. Keywords: add-backs; disclosure; housing need; matrimonial and non-matrimonial property; needs; conditional order

SM v BA & Anor (WD) (No 3 Amendments to Statement of Case) [2026] EWFC 9 (Nicholas Allen KC, sitting as a deputy High Court Judge)

Beware of the consequences of very late applications to amend a statement of case. Keywords: TLATA; case management