Re L (Article 13: Protective Measures)(No.2) [2023] EWHC 140 (Fam)

Judgment of Mr Justice Cobb in proceedings under the 1980 Hague Convention in which he dismissed the father’s application for summary return of the child and set aside the return order made in Re L (Article 13: Protective Measures)(No.1) [2022] EWHC 3427 (Fam), the father having not complied with the ‘condition – precedent’ within a reasonable time and having demonstrated insufficient engagement with the process of achieving it.