Internal Relocation

The Custody Minefield Factsheets – Smartphone Series (optimised for smartphone users). Copyright Michael Robinson 2010, 2011. Crown Copyright material is reproduced with the permission of the Controller of HMSO and the Queen's printer for Scotland.

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Contents

Introduction

The objecting parent’s choices

Shared Residence over distance

Human Rights and other considerations

Psychological harm to the primary carer if their application is refused

Research Supporting Co-Parenting

Evidence and the Distress Argument

Promoting contact with the other parent

Judgments in Internal Relocation Cases

Restrictions on Residence Orders

In Summary (and our interpretation of the current authorities)

Applying to Court

Finding your local Court

The Relocation Campaign

Support

See also our separate smart phone sheet on Internal Relocation Case Law Summaries.

Introduction <Back to Top>

One of the hardest set of circumstances for parents and the court is where one parent seeks to move some distance from the other, and the move will disrupt the relationship and/or time that the child(ren) spend with their other parent.

If the parent wishing to move has sole residence, they do not normally have to seek the court's permission to relocate with the children, although the practicality of arrangements set down in any existing contact order may make an application to the court necessary to vary the contact pattern. In such circumstances, the non-resident parent may have chosen to apply to the courts for a prohibitive steps order (to prevent the move) and/or have applied for residence (so that the child will come to live with them, should the other parent carry through their plan to move).

The objecting parent's choices <Back to Top>

A number of choices are available to the parent seeking to prevent their child from moving:

  1. Accept that the children will move, and seek a contact order which ensures that lost parenting time is made up through an increase in holiday time (as seen in the case law Re: F) or weekends (if practical).
  2. Apply for a Prohibited Steps Order to prevent the children moving (this should be done urgently if the move is imminent, and urgently if you are unsure whether the move is imminent),
  3. To apply for sole residence or shared residence, with the child spending term time with themselves, with weekend contact for the other parent if distance allows, and time during school holidays with relocating parent. Practical arrangements need to be considered as part of the opposing parent's case in the event that the court refuses permission for the children to relocate but the relocating parent goes ahead with their move.
  4. We would always urge that before heading to court, parents enter mediation. However, if there is any question of the move proceeding without the relocating parent seeking the court's permission or non-resident parent's consent, do not delay applying for a Prohibited Steps Order.

The preferred choice and its possibility of success is dependent on the parents' individual circumstances.

Few would argue that a primary carer's wish to move with the children is unlikely to be denied (in light of existing precedents) unless there are compelling reasons to do so. These would include the primary carer's wishing to diminish the relationship between the child and the child's other parent through geographic distance, if their plans were impractical or ill-conceived, if the child is of sufficient maturity to understand the implications of the move (is Gillick Competent) and does not wish to relocate, or if there are serious welfare considerations.

Shared Residence over distance <Back to Top>

It is worth noting the judgment in Re F and the comments by Lord Justice Thorpe and Lord Justice Wilson on the subject of shared residence over distance (where the mother relocated from Hampshire to Scotland, and the court agreed that the children relocate but also made a shared residence order):

'The judge's approach is in my opinion founded on sound principle. As this court has said recently, a shared residence order must reflect the underlying reality of where the children live their lives. The fact that the parents' homes are separated by a considerable distance does not preclude the possibility that the children's year will be divided between the homes of the two separated parents in such a ways as to validate the making of a shared residence order. This case is a good example of how, in reality, the order expressed by the judge, in providing for the contingency that the mother moves to Scotland and the father remains in England, results in a routine that sees the girls established in an Edinburgh home during the school terms times, and in a Hampshire home during the school holidays. My Lord has worked out the extent to which the mother's half share of the main school holidays will be eroded if the father foregoes much of his term time weekend contact. In reality the mother will be paired down to her irreducible minimum of 12 days. That ensures that the children will have their father's home as their home during school half terms and almost all the school holidays' - Lord Justice Thorpe

'But like my Lord, I consider it perfectly apt to say, without stretching language, that, were the girls to spend term-time with the mother in Edinburgh and all half-terms and almost all school holidays with the father in Hampshire, they would have the benefit of residence with each parent in each of the homes.' - Lord Justice Wilson

Human Rights and other considerations <Back to Top>

When the case comes to court, there are conflicting human rights issues to consider:

While parental human rights are important, any decision of the court must be based on what is in the child's best interests. This and other matters must be considered:

The above points mirror those that a court must consider in international leave to remove cases. They are often referred to as hurdles that the parents should be expected to satisfy when presenting their case. That said, in an international leave to remove case, the hurdles are higher, in that the impact on all concerned and risks presented by the move are greater. Once the child has left the UK court's jurisdiction, problems over contact and non-compliance with orders are typically beyond the UK court's control.

There are other factors which may be considered when a court reaches a judgment, and each case will have its own peculiarities. Is the moving parent 'heading home'? Are there any mental health or addiction problems concerning either parent? Does the child have any special needs which one or other of the parents can better meet in their preferred location? Are relationships with the extended family to be considered? What is the strength of family support in each location?

Psychological harm to the primary carer if their application is refused <Back to Top>

One argument in favour of a relocation proceeding is given considerable weight in both internal relocation and leave to remove cases (relocation abroad), and this is 'the likely psychological harm that the primary carer will suffer should their application be refused and the belief that this will cause harm to the children'. In judgments which provide the authorities on these matters, the primary carer is referred to as 'her', being the mother. 

In the case Re S and Payne v Payne, Lord Justice Thorpe comments that such opinions have been held in relocation cases for 30 years.

In the case Re B (A Child) [2007] EWCA Civ 1055, Lord Justice Thorpe who gave the leading judgment (in that case), made reference to a legal guide on the subject of international relocation by Professor Lowe, entitled 'International Movement of Children' (Jordan Publishing Ltd, 2004)[1]. He endorsed Professor Lowe's conclusion that:

'a primary carer faced with an application for a prohibited steps order or the imposition of conditions on a residence order, will not, save in an exceptional case, be restrained by the court, because for the court so to do would be an unsustainable restriction on adult liberties and would be likely to have an adverse effect on the welfare of the child by denying the primary carer reasonable freedom of choice.'

This passage supported Lord Justice Thorpe's own view from 2001 in the case Payne v Payne which remains the leading judgment for international leave to remove cases. Lord Justice Thorpe stated:

26. In summary a review of the decisions of this court over the course of the last thirty years demonstrates that relocation cases have been consistently decided upon the application of the following two propositions:

(a) the welfare of the child is the paramount consideration; and

(b) refusing the primary carer's reasonable proposals for the relocation of her family life is likely to impact detrimentally on the welfare of her dependent children. Therefore her application to relocate will be granted unless the court concludes that it is incompatible with the welfare of the children.

It is worth noting two things. The first is that Professor Lowe is a professor of law, and not psychology. The second is that, to my knowledge, there is no psychological study that supports his or Lord Justice Thorpe's opinion. More concerning is that there are no shortage of studies that confirm that a child's welfare is adversely affected when deprived of one parent, or where time with one parent is suddenly changed. The court pays too much attention to an unqualified and somewhat historic opinion, and not enough to arguments which are supported by considerable research.

Research Supporting Co-Parenting <Back to Top>

Consider four studies published in recent years. I have placed an emphasis on the parts of the research that relate to fathers, and have done so since, in court, it is rare that one has to produce an argument that mums are important. The research clearly supports that fathers have an equally essential role (as do mothers), and deprivation of a father causes harm. It may not be a fashionable view in our current society, but it is one supported by psychologists and educational professionals:

a)  The February 2009 Children's Society Report based on the experiences of 30,000 children found that 'a child's performance at secondary school, self-esteem and well being as an adult is linked especially to the father's input'  and 'children are 40% more likely to suffer mental health problems when separated from their fathers' and 'On average, children are less likely to fail at school or suffer depression the more they see their separated father.'

b] The 2003 Department for Education and Skill's own research which concluded 'Fathers play an extremely important role in their children's lives and a plethora of research indicates that father involvement is significantly related to positive child outcomes' and 'Father involvement in children's education at age 7 predicts higher educational attainment by age 20, in both boys and girls.'

c] The report by the University of British Columbia published in December 2008 entitled 'Child Custody, Access and Parental Responsibility' found that 'Sole maternal custody often leads to parental alienation and father absence which is associated with negative child outcomes.' The research discovered that '85% of youth in prison are fatherless', '71% of high school dropouts are fatherless', '90% of runaway children are fatherless', 'and fatherless youth exhibit higher levels of depression and suicide, delinquency, promiscuity and teen pregnancy, behavioural problems and illicit and licit substance abuse.' Equally as concerning were the findings of these and a wide range of other reports that concluded 'These studies found that fatherless youth are more likely to be victims of exploitation and abuse, as father absence through divorce is strongly associated with diminished self-concepts in children (Parish 1987).' Not much has changed since 1987, and indeed, in the area of internal relocation and leave to remove and as Lord Justice Thorpe states, the court's attitude has remained unchanged for 30 years, as have the outcomes for children.

d] 'Children in joint custody arrangements fare significantly better on all adjustment measures than children who live in sole custody arrangements' [Bauserman 2000]

There is much disagreement over the precedent from case law which governs relocation cases (notably Poel v Poel and Payne v Payne) which  undoubtedly continue to influence court decisions in internal relocation cases (as seen in the cases Re S and Re B). Legal decisions should ideally be based on expert evidence but often aren't, and educational, psychological and social research findings are too often ignored. Sadly, the courts continue to be bound by guidance in external relocation cases which many consider out-of-date (too much weight is given to the relocating parent's feelings and wishes rather than the children's emotional and developmental needs and welfare). 

Evidence and the Distress Argument <Back to Top>

In a 2009 international leave to remove case, Re W, the trial judge challenged counsel's argument that the mother would be psychologically harmed should her application be refused. The Judge accepted that there was no evidence to suggest that the mother would suffer any more than disappointment, and refused her application. The mother appealed the decision, and her counsel criticised the Judge for his view. In the Court of Appeal, Lord Justice Wall found that the Judge was entitled to reach that conclusion based on the evidence before him. Rather confusingly, this judgment by Lord Justice Wall seemingly only upheld the trial judge's discretionary right to reach the conclusion he did, while the guidance which states that no evidence need be supplied by the mother to confirm she will suffer psychological harm at her application being refused remains (as per the case Re G (Children) [2005] FLR 166). The case law conflicts, and in reality is dependent on the trial judge's opinion and Court of Appeal's actions to uphold trial judges' discretionary rights or their own earlier guidance.

The Judge in Re W, on the matter of the impact of refusal on the mother, had said:

28. It is a very important consideration.  I have to say that I have no medical evidence of significant depression.  I heard the mother come back when she was re-called and say that she was suffering and would suffer more if I turned her down.  Mr Rowlands put it well when he said there will be very great unhappiness as a result of my decision one side or the other.  The father also has had to have some medicaments for depression.  It is not a case where I am able to say that the mother will be so savagely or severely damaged that this will get through to the children.  She will be disappointed but she will have to consider what she can best do to overcome it if I turn down her application.

The trial judge was right that the psychological impact of refusal on the primary carer is one factor among others of equal and arguably greater importance. There is much controversy at the courts current position on what is referred to as the 'distress argument', but in many cases, 'the psychological impact on the primary carer' is the trump card in the barrister's deck of arguments.

The strength of the relationship between children and a non-resident parent can be equally as strong as that of the primary carer, and research confirms that the disruption to or diminishing of that relationship carries welfare risks to the child.

Promoting contact with the other parent <Back to Top>

In the leave to remove case M v H [2008] EWCA 324 (Fam), the "most significant factor" was each parent's willingness to promote contact between the child and their other parent. The child remained in England with the father. There had been historic problems over contact, and while both parents' behaviour was less than ideal, the father was deemed more likely to promote contact. It should also be noted that the mother had previously sought to mislead the court.

In the case B v B (Residence: Condition Limiting Geographic Area) [2004] 2 FLR 979, the mother's willingness to mislead the court  and father on a number of very serious issues was a key factor in the relocation being prevented. It is more likely in the current climate, that a solution seen in Re T, a Prohibited Steps Order being made, or residence being granted to the non-relocating parent would be the court's preferred outcome rather than a residence order with restrictions.

Judgments in Internal Relocation Cases <Back to Top>

The court has a number of options when deciding the outcome of an internal relocation case:

Restrictions on Residence Orders <Back to Top>

Section 11(7) of the Children Act 1989 allows for conditions to be included in residence orders. However, in the case Re E (Residence: Imposition of Conditions) [1997] 2 FLR 638, Dame Elizabeth Butler-Sloss, when she gave the leading judgment (in that case), said:

Section 11(7) applies to all four section 8 orders, including prohibited steps orders and specific issue orders. The wording of the subsection is wide enough to give the court the power to make an order restricting the right of residence to a specified place within the UK. But in my view a restriction upon the right of the carer of the child to choose where to live sits uneasily with the general understanding of what is meant by a residence order.

In 2007 in the court of appeal and in the case Re B (A Child) [2007] EWCA Civ 1055, Dame Elizabeth Butler-Sloss's earlier guidance was upheld. 

In Re D (Minors) (Residence: Imposition of Conditions) [1996] 2 FLR 281, Lord Justice Ward said:

'The court was not in a position to overrule her decision to live her life as she chose. What was before the court was the issue of whether she should have the children living with her.’

In his guide, Professor Lowe states:

‘The correct approach, therefore, is to look at the issue of where the children will live as one of the relevant factors in the context of the cross-applications for residence, and not as a separate issue divorced from the question of residence. If the case is finely balanced between the respective advantages and disadvantages of the parents, the proposals put forward by each parent will assume considerable importance. If one parent’s plan is to remove the children against their wishes to a part of the country less suitable for them, it is an important factor to be taken into account by the court and might persuade the court in some cases to make a residence order in favour of the other parent.’

The court has generally favoured resolving internal relocation cases by deciding with whom the children should live (although as seen in the more recent case Re T, the issue was resolved via a shared residence order with the parenting schedule determining that the father provided midweek care, and this prevented the relocation). In the case Re F (Children} [2010] EWCA Civ 1428 we see the trial judge granting a Prohibited Steps Order which prohibited the children relocating to Stronsay in Scotland.

Imposition of restrictions on where a child may live by way of conditions on a residence order or granting of a Prohibited Steps Order is possible,  although the likelihood of a successful appeal makes it a decision that most judges would view with caution. It should be noted that any restrictions applied for should be on where the child, and not the relocating parent lives (although such an outcome may well impact on where the parents choose to live).

In Summary (and our interpretation of the current authorities) <Back to Top>

If the Court decides that a relocation should not proceed, it is unlikely to favour Prohibited Steps Order or Residence Order with conditions as to where the primary carer should live. Rather, if the court accepts that the move is not in the children's best interests, it may make a Prohibited Steps Order restricting where the children are to reside, or vary residence.

A parent's right to live where they want carries considerable weight, and the court is highly unlikely to stop them from moving, although may, based on child welfare considerations and the plans and motives of the parties, decide that it is not in the child's best interests to relocate.

There is finally case law which challenges the argument that denial of their request to relocate with the children will cause the parent seeking to move psychological harm which is so severe that it will impact on their care of the children. Evidence which either supports or opposes that argument should be put forward by the parties to support their case.

The court is unlikely to deny a primary carer's wish to relocate, unless there are strong welfare grounds to do so, or if it can be shown that their motives and/or plans are unreasonable or unrealistic and/or that there exceptional circumstances. If it is argued in court that exceptional circumstances need be shown to prohibit the children's move, as might be implied by the guidance from the case Re E (Residence:Imposition of Conditions) [1997] 2 FLR 638 (see below for links), the parent opposing the move should raise Lord Justice Wilson's recent concern that the need to show a case is exceptional casts an impermissible gloss on considerations regarding the children's welfare (which, under the Children Act 1989, must be paramount) - ref Re F (Children) [2010] EWCA Civ 1428 (at paragraph 26... see below for links).

Applying to Court <Back to Top>

You need to download Form C100 to apply for a Prohibited Steps Order. You can find this form on our Court Forms page (requires Adobe Acrobat to open). Complete Form C100 and take three copies to your local family court and ask for their administration department.

There will be a charge for applying to the court, and you will find the current fee for a Prohibited Steps Order at paragraph 2.1(d) on our Court Fees sheet. If you are on benefits or suffering financial hardship, you may get assistance with the court fee. Ask the court’s administration department staff for assistance regarding this.

If you wish to apply for residence at the same time, in the event that the court refuses permission for the children to relocate but the other parent still moves, also specify this on the C100 Form.

Before setting off for the court building, ensure you have with you three completed and signed copies of the Form C100 and the cash, cheque or postal order to pay the court fee. After taking the forms and payment to court, you will be provided with Notices of Proceedings (Forms C6A) and a Form C9. There will be a Notice of Proceedings for each party, telling each what they should do next, and informing you of the date and time of the first directions hearing before the court.

If you are the one applying for the order, it is up to you to serve (deliver or post) copies of the court forms on the other parties. After having done this, you must complete Form C9 confirming when you served the paperwork on the other parties, and send this form back to the court.

Finding your local Court <Back to Top>

Find out where your local County Court is, and check to see whether they handle family related cases. If not, you need to locate one which does. You can use HMCS Court Finder to do this. Once on that website, enter in your region under ‘Court Region Search’. Then make sure that ‘Court Work Type Search’ is set to ‘Family Work’. Then search under ‘Court Type’ and do a search first on ‘Combined Crown and County Court’, then ‘County and Magistrates Court’, and then ‘County Court and District Registry’. Choose the court which is closest to where you or your children live and print the details.

The Relocation Campaign <Back to Top>

We recommend you visit our campaign website www.relocationcampaign.co.uk and download our Parliamentary Briefing Report. This calls for improved legislation to better protect child welfare in relocation cases. Also, refer to our shared care research pages which may provide information to support your arguments before the court.

Support <Back to Top>

The Custody Minefield offers support forums where you can ask our team of experienced support staff questions about family law, the courts and separation. Collectively, we have answered more than 10,000 posts on other family law related support forums. Visit our Support Forum Page on The Custody Minefield website to find out how to register.

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[1] International Movement of Children (Practice and Procedure), Nigel V.Lowe, Mark Everall,  Michael Nicholls (Jordan Publishing Ltd, 2004)

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