FD24P00634 - [2025] EWHC 900 (Fam)

As I have set out above, the relationship between the mother and father was no more than a fleeting encounter which, as Jackson LJ indicated at paragraph 89.6(3) of A, B & C, will fall at one end of the spectrum when assessing the substance of the relationship. Accordingly, it is to be afforded less weight than e.g. in a case where there has been a meaningful or substantial relationship.

As to the mother’s extended family it is only those relatives in South Africa who have any potential to be considered and the relationship with the mother is not a close one. The limited nature of the relationship with X combined with the fact that they are out of the jurisdiction suggests (to answer the question posed by Jackson LJ at paragraph 89.6(3) of A, B & C) that they would not have a significant degree of objective justification to complain if they later discovered they had been excluded from the decision about Y’s future.