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Judgment: The father sought the summary return of his son to California. HHJ Robertshaw allowed oral evidence on the issue of acquiescence but found that very little of value or relevance was gained. The written communications did not support a defence of acquiescence under Article 13(a), and the judge was satisfied that adequate arrangements could be made to secure the child's protection after his return, so the defence under Article 13(b) (grave risk of harm/intolerability) also failed. A return order was made.

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