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Judgment: The father appealed against the dismissal of his application for a prohibited steps order, which would have prevented the mother taking their child to Iraq. He argued that the judge had not adequately considered the risk of the child not being returned, nor whether the child would be safe in Iraq. However, Russell J DBE found that the judgment was wholly concerned with the child's welfare, the risk of the mother retaining the child was low, and indeed the greater risk of wrongful retention lay with the father. The appeal was dismissed.

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