S v D (Hague Convention: Domestic Abuse: Undertakings: Return to Third State [2019] EWHC 56 (Fam)

Judgment of Cobb J considering a father’s application under the Hague Convention and Article 11 of Council Regulation (EC) 2201/2003 seeking the return of his son to Hungary, despite the parties being habitually resident in Germany at the time of the child’s removal. The decision considers the use of undertakings to protect against the grave risk of harm to the child if his return is ordered.