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News: The Court of Appeal recently gave judgment in Read v Panzone & Anor [2019] EWCA Civ 1662, an appeal concerning s37 of the Matrimonial Causes Act 1973. The Court gave significant warnings to first instance judges about the dangers of making findings of fact on alternate bases: although judges may be tempted to take this ‘belt and braces’ approach, it may simply muddy the waters and confuse the issues for the parties.

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