Damian Garrido QC and Rob George in leading internal relocation appeal


21st Dec 2015 | News


Damian Garrido QC and Dr Rob George appeared for the intervener, the International Centre for Family Law, Policy and Practice, in the new leading case on relocation within the United Kingdom, Re C (Internal Relocation) [2015] EWCA Civ 1305, which was handed down on 18 December 2015.

This important new case establishes that internal relocation cases are not governed by any test of ‘exceptionality’, but are pure welfare determinations. Internal relocation cases are to be treated in the same way as international relocation cases, though bearing in mind that the factual assessment of each case will be different depending on the distance involved and the impact that the move would have on the child’s relationship with the non-moving parent, amongst other factors.

The Court of Appeal’s summary of the development of the law follows the skeleton argument filed by Damian and Rob, whose “comprehensive submissions” were praised by Black LJ.

The Court of Appeal judgment is available here.


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