Case No. UKUT-00180-(IAC)

was valid for the purposes of Dutch law. This approach was contrary to the decisions in Kareem (Proxy marriages – EU law) [2014] UKUT 00024 (IAC) ( Kareem ) and TA and Others (Kareem explained) Ghana [2014] UKUT 00316 (IAC) ( TA ). 3. It is important to note that although the decision of the First-tier Tribunal was set aside, certain findings were expressly preserved: first, that the previous customary marriage of the claimant’s Dutch husband, Mr Raymond Awuah , had been validly dissolved in 2012; second, that the proxy marriage contracted between the claimant and Mr Awuah in Ghana was valid according to the law of that country. 4. Thus, as was clearly stated in the error of law decision, the issue before us now is a narrow one: is the marriage in question valid for the purposes of Dutch law?