Re P and Q (Hague Convention: Consent) (Costs) [2021] EWHC 2186 (Fam)

Judgment: The mother applied for a costs order following the dismissal of the father's applications for return orders under the Hague Convention 1980 or the inherent jurisdiction in respect of their two daughters, aged 11 and 12. Poole J concluded that, although the father's conduct could not, in general, be characterised as unreasonable or reprehensible, he had been guilty of unreasonable conduct in making a wholly unnecessary application for a location order, and doing so without notice. Still, the costs order should be reasonable and proportionate, and the direct costs to the mother of that application would have been a relatively small part of her total costs, which came to £27,316.10 inclusive of VAT. Poole J ordered the father to pay her costs in the summarily assessed sum of £4,000 plus VAT of £800, a total of £4,800. This was a reasonable sum having regard to all the circumstances including the financial circumstances of the parties and their conduct in relation to the dispute.