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Judgment: The mother made an application under the Hague Convention for the return of the son to New Zealand. The father had expressed concerns about the child's well-being in his mother's care. Darren Howe QC had to proceed on the basis that there was a risk of harm, but he noted that there had been improvements in the mother's parenting, and accepted her undertaking to prevent contact between her partner and the child. The father had not proved a grave risk of harm or an otherwise intolerable situation for the son and the defence therefore failed. An order would be made for the return of the son to New Zealand.

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