“I believe that [the mother] does want to go and see her family, but she is actually very content with her life in this country and would not want to give that up. Therefore, my decision at this point is that she should be entitled to take [N] to Kenya. However, I do not think it is as simple as that at this stage. There needs to be some more reassurance put in place, because whilst I can see that the risk is not that great, we have to ameliorate that risk as much as possible. It is about reassuring [the father] as much as it is about securing [N’s] return. … However, I do need further reassurance myself by the processes I have described and discussed.”
“… It seems to me trite to say, and both parties agree that it is the case, that in relation to [N] in particular the magnitude of the consequences of a breach are great. She would be in a country with which she has no roots other than it is her mother’s place of birth, and her aunts and uncles live there. It is a country that [she] has visited on one occasion for a period of a fortnight. It is a country whose culture is unfamiliar to her. It is a country where she would possibly not have the education that she would have in this country. It is a country where her father would not be able to fight to get her back into this country. It would consequently damage and effectively destroy the relationship she has with her father. … Therefore the consequences of the breach are huge.”
“There is obviously in this case the possibility of notarised agreements. There is the possibility of mirror orders. The financial circumstances of the parties put beyond reality the adoption of a monetary bond. There should have been an exploration of those practicalities in this case through expert evidence, and there was not. That should have been seen by the judge as a fundamental deficiency that was not to be cured by an evaluation of the father's responsibility, drawn from the history, nor a judicial evaluation of probabilities in relation to the performance of the contact order.”
“[23] It is not at all clear from the judgment what the judge thought would be the means of enforcing a notarised agreement in Cameroon, in any event. One might have thought from the judgment that she had some knowledge of the situation in Cameroon, but, if she did, she did not spell it out. It is precisely the sort of matter – the question of enforcement in the Cameroon – that an expert would have assisted with. How was the child to be returned to this country if the father did not comply with his obligation to return [the child]? Would a notarised agreement be possible at all and, if so, would it help? Would a mirror order in the Cameroon courts be possible and/or desirable, and so on? Those are the questions that needed to be answered.” [24] Whilst I would not want to be thought to be saying that no application of this type can proceed without expert evidence to deal with the practicalities of the foreign legal system and how a return from a non-Hague Convention country could proceed if the child were not returned, it is in my view, incumbent on a judge to approach the matter in accordance with Re K with an inclination that such expert evidence will be necessary and, if he or she concludes it is not necessary, to explain very clearly why what might be classed as normal practice is not required in a particular case.”
“… The question I need to ask myself afresh given that the course of action is no longer available is: are there still sufficient safeguards in place to assure me that [the mother] will return with [N] on 22nd August? 8. As part of my consideration I bear in mind everything I said in my Judgment in April, the documents that I have referred to which were given to me today and a draft order prepared by Ms Okine which she handed in this morning. Weighing everything together and bearing in mind my earlier view that [the mother] regards herself as a British Citizen first and foremost and wishes to remain a British Citizen I am satisfied that notwithstanding the British FCO’s unwillingness to agree the lodging of the passport that there are sufficient safeguards. I bear in mind again that [the mother] has had the passport since late last year and if she really wished to take [N] away she could have done it long ago. Likewise this application has been before me since last April and [the mother] has worked very hard to put things in place. Everything I see tells me this is a woman who abides by orders and she will return to the jurisdiction.”