Family Law Hub

Moher v Moher [2019] EWCA Civ 1482

The husband appealed from a financial remedy order, arguing that it contained neither a sufficient evaluation of his undisclosed financial resources nor a sufficient explanation for the award of a £1.4 million lump sum. Moylan LJ noted that the absence of a structured s 25 analysis in the judgment below, or of an exposition of how the award was calculated, had provided scope for the appeal. He did not accept, however, that a judge is required to provide a figure or bracket in every case when confronted by non-disclosure. In this case, the judge's determination of the husband's resources had been sufficient, and the award was based on a sound assessment of the wife's needs. King LJ and Rose LJ agreed and the appeal was dismissed.

Judgment, published: 30/08/2019

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Published: 30/08/2019

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