CA-2024-002756 - [2025] EWCA Civ 1038

We were shown some dictionary definitions of “stepchild”. The Concise Oxford English Dictionary (2006 edition) defines “step-” thus:

“… denoting a relationship resulting from a remarriage.”

The definition of “stepchild” in that dictionary is:

“a child of one’s husband or wife by a previous marriage.”

The Concise Oxford Dictionary (12^th ed) (2011) has the same definition.

As mentioned, the online Oxford English Dictionary (updated in 2023) has the following definition:

“A person who is related to another as a result of a subsequent marriage or relationship of a parent, rather than through blood; a stepchild, step-parent, step-sibling etc.”

The definition in the on-line version of the Oxford English Dictionary is, I think, an outlier. Other dictionaries give other definitions. The printed version of the Oxford English Dictionary defines “step” as:

“… prefixed to terms of relationship (as son, father, brother) to form designations for the degrees of affinity resulting from the remarriage of a widowed parent.”

The Shorter Oxford English Dictionary (6^th ed) (2007) has:

“step- forming words denoting a person in a familial relation but unrelated biologically, orig. through a marriage to a widower or widow with one or more children later through any marriage or marital relationship between persons either or both of whom have a child or children by another partner.”

The Oxford Dictionary of English (3^rd ed) (2010) has:

“stepchild a child of one’s husband or wife by a previous marriage”

Chambers Dictionary (13^th ed) (2014) has:

“stepchild … a wife’s or husband’s but not one’s own child, daughter or son.”

We were also shown an extract from R v Miller [2001] NSWCCA 209 in which Giles JA referred to a number of dictionary definitions, concluding at [29]:

“The meanings have also been recognised in the cases as the meaning according to ordinary usage, with marriage between the step-parent and the parent of the child a necessary ingredient.”