FA-2025-000004 - [2025] EWHC 638 (Fam)

Whenever a party seeks an adjournment of the decision hearing to consider whether to make an application for permission to appeal or to prepare for it, they should also seek an extension of time (see McDonald v Rose para. 21(5)). The Court of Appeal was very clear that, even though a decision hearing may be adjourned, the 21 days (within which an appeal must be filed, in accordance with the FPR) run from the date the decision was formally announced and not the date that the formal order recording the decision was issued. Underhill LJ regarded this as “uncontroversial” and considered that it “should be known to any practitioner, though experience shows it is often overlooked”.