Part III: a second bite of the cherry?
Rhiannon Lewis
Dawson Cornwell
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Part III: a second bite of the cherry?
Introduction
Part III of the Matrimonial and Family Proceedings Act 1984 allows the English courts to
make orders for financial relief following a divorce overseas, even where financial orders
were granted in those overseas proceedings.
Jurisdiction
In order to apply under Part III, the applicant must establish:

that the overseas divorce is recognised as valid in England and Wales; AND

that the applicant has jurisdiction to issue in England and Wales.
Part III applies also to overseas legal or judicial separations and annulments.1 In addition
there is equivalent legislation in relation to overseas relationships treated as civil
partnerships. 2
Recognition of overseas divorces
The starting point is whether or not the divorce itself is capable of recognition in England. If
the divorce is not capable of recognition, then the parties are still legally married under the
eyes of the English law and can therefore seek a divorce in England followed by an
application for financial provision.
The issue of recognition of overseas divorces is dealt with in more detail in an attached
appendix. However, for the purposes of the rest of this paper, it is assumed that there has
been an overseas divorce which is capable of recognition in England and Wales.
Remarriage a bar to application
An application under Part III cannot be brought where the Applicant has remarried, even if
that marriage is void or voidable (s. 12(2) and (3) FLA 1986). Remarriage by the potential
Respondent however, does not prevent an Applicant from initiating proceedings for a Part III
order.
1
2
Section 12(1) Part III
Schedule 7 Civil Partnership Act 2004
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Jurisdiction to issue
Jurisdiction to apply under Part III can be established in one of three ways (s. 15 MFPA
1984):
15 Jurisdiction of the court
(1) Subject to [subsections (1A) and (2)] below, the court shall have jurisdiction
to entertain an application for an order for financial relief if any of the following
jurisdictional requirements are satisfied, that is to say—
(a) either of the parties to the marriage was domiciled in England and Wales
on the date of the application for leave under section 13 above or was so
domiciled on the date on which the divorce, annulment or legal separation
obtained in the overseas country took effect in that country; or
(b) either of the parties to the marriage was habitually resident in England and
Wales throughout the period of one year ending with the date of the
application for leave or was so resident throughout the period of one year
ending with the date on which the divorce, annulment or legal separation
obtained in the overseas country took effect in that country; or
(c) either or both of the parties to the marriage had at the date of the
application for leave a beneficial interest in possession in a dwelling-house
situated in England or Wales which was at some time during the marriage a
matrimonial home of the parties to the marriage.
The grounds for jurisdiction are not the same as the grounds for issuing a divorce Petition in
England.
Where jurisdiction is based on (c) above, the financial provision that the court can make is
effectively restricted to that dwelling house (see below).
However, there may be more than one matrimonial home and a party may reside between two
homes in separate countries (Otobo [2003] 1 FLR 192). Foreign practitioners need to be
aware that reference is made to a beneficial interest only. Hence it may not be immediately
obvious whether a party has a beneficial interest in a property – the property could on the
face of it, for example, be in the name of someone outside the marriage.
Lugano Convention Country/EU State
Where an application is made following a divorce in a Lugano Convention or EU state, then
different jurisdictional rules will apply.
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Two Stage process
An application under Part III is effectively a two stage process. First the applicant must
apply for leave under section 13. Secondly, if the application obtains leave, then he can issue
his application under Part III.
Stage One: Leave of the court
An applicant for a Part III order must first seek leave of the court. This must be done without
notice in the High Court.
It is not enough simply to demonstrate that the court has jurisdiction for the making of an
application. A court cannot grant leave unless it considers that there is a „substantial ground
for the making of an application” (s. 13(1) MFPA 1984):
13 Leave of the court required for applications for financial relief
(1) No application for an order for financial relief shall be made under this Part
of this Act unless the leave of the court has been obtained in accordance with
rules of court; and the court shall not grant leave unless it considers that there is
substantial ground for the making of an application for such an order.
The court will look at the merits of the case as a whole. It must consider whether England and
Wales is the “appropriate venue” for the application, by reference to the criteria set out under
section 16 MFPA 1984:
16 Duty of the court to consider whether England and Wales is appropriate venue
for application
(1) [Subject to subsection (3),] before making an order for financial relief the
court shall consider whether in all the circumstances of the case it would be
appropriate for such an order to be made by a court in England and Wales, and if
the court is not satisfied that it would be appropriate, the court shall dismiss the
application.
(2) The court shall in particular have regard to the following matters—
(a) the connection which the parties to the marriage have with England and
Wales;
(b) the connection which those parties have with the country in which the
marriage was dissolved or annulled or in which they were legally separated;
(c) the connection which those parties have with any other country outside
England and Wales;
(d) any financial benefit which the applicant or a child of the family has
received, or is likely to receive, in consequence of the divorce, annulment or
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legal separation, by virtue of any agreement or the operation of the law of a
country outside England and Wales;
(e) in a case where an order has been made by a court in a country outside
England and Wales requiring the other party to the marriage to make any
payment or transfer any property for the benefit of the applicant or a child of
the family, the financial relief given by the order and the extent to which the
order has been complied with or is likely to be complied with;
(f) any right which the applicant has, or has had, to apply for financial relief
from the other party to the marriage under the law of any country outside
England and Wales and if the applicant has omitted to exercise that right the
reason for that omission;
(g) the availability in England and Wales of any property in respect of which
an order under this Part of this Act in favour of the applicant could be made;
(h) the extent to which any order made under this Part of this Act is likely to be
enforceable;
(i) the length of time which has elapsed since the date of the divorce,
annulment or legal separation.
Whether or not leave will be granted will depend on the facts of each case.
If adequate provision has already been made abroad that is likely to be enforceable (s.
16(2)(h) MFPA 1984) for example, it may be less likely that leave will be granted. Similarly,
if there has been a long unexplained delay since the divorce (s. 16(2)(i) MFPA 1984) and the
parties have, although satisfying one of the jurisdictional grounds above, lived for the
majority of their marriage abroad and have strong cultural ties with that country (s. 16(2)(b)
MFPA 1984), it may again mean that it is less likely that leave will be granted.
Respondent to order granting leave
Applications to set aside orders granting leave are discouraged.
In Agbaje Lord Collins considered that, unless the Respondent could deliver a “knockout
blow” any application to set aside should be adjourned to be heard with the substantive
application.
Judicial comity
Previously, the courts were reluctant to grant leave in Part III cases due to the difficulties in
principle of a court in England acting effectively as an appellate court in relation to
judgments made in other countries. It was seen to go against the principle of judicial comity
and finality in proceedings; it also adds to cost and time being expended and, on a cynical
view, gives Applicants a „second bite of the cherry‟.
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In Holmes [1989] 2 FLR 364 for example, Lord Justice Russell went as far as saying:
“Prima facie the order of the foreign court should prevail save in exceptional
circumstances, and a good case for any interference with it or adjustment of it or any
supplementation of it should be apparent before any leave is granted under s 13
where the foreign court is properly seized of the dispute, as it was in this case. So far
as it is possible, duplicity of proceedings should be avoided in this as in all other
fields in the interests of the parties and their children as well as in the interests of
justice and the comity of nations. In my judgment this court should be very slow
indeed to interfere with the discretion which was exercised by Heilbron, J.”
The courts in the 1990‟s and early 2000‟s thereafter exercised a cautious approach in relation
to the granting of leave.
However, the judicial approach began to move away from this previously restrictive
approach.
Threshold
However, the leading case of Agbaje v Akinnoye-Agbaje [2010] UKSC 13 now confirms that
the court now adopts a lower threshold in the granting of leave than the approach the court
had endorsed 21 years ago in Holmes.
Although the threshold has been lowered, the Supreme Court in Agbaje added that the
threshold is higher than merely having a „serious issue to be tried‟ or a „good arguable case‟.
Forum conveniens
Forum conveniens does not apply to Part III. It is not a choice between jurisdictions. It is
quite possible for two jurisdictions to be involved; one in respect of the divorce and the other
in respect of the financial orders.
It matters not whether there was a financial award made in a jurisdiction outside England and
Wales which was, in fact, the most convenient forum. As Lord Collins said in Agbaje:
“The task for the judge under Part III is to determine whether it would be
appropriate for an order to be made in England, taking account in particular of the
factors in section 16(2), notwithstanding that the divorce proceedings were in a
foreign country which may well have been the more appropriate forum for the
divorce.” (para. 50).
However, the court must weigh in the balance, the connections with England and Wales
against the connections with the overseas jurisdiction.
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Stage Two: what orders can be made?
If a court grants leave for a Part III application, the court will then consider which orders to
make in line with English law.
Section 17 MFPA 1984 imports the same remedies available to English courts under sections
23 and 24 of the MCA 1973. These include:
Property adjustment: this includes the transfer of a property from a husband‟s sole name to a
wife‟s sole name or from the parties‟ joint names to either the husband or wife individually.
The court also has the power to order a sale of a family home or a party‟s shares in a family
business.

Lump sum: this may include capitalised maintenance which is intended to pay one
party a sum large enough for them to invest and be provided for in lieu of regular
maintenance payments. Lump sums may be payable in one payment or in instalments
which, unlike maintenance payments, are not variable.

Pension sharing

Periodical payments: periodical payments may be payable on a „joint-lives‟ basis (i.e.
until the payee dies or re-marries) or for a fixed term. The court also has the power to
prevent any future application by the payee to have that fixed term extended.

Interim maintenance: it must be shown that there is an „immediate need of financial
assistance‟ (s. 14(1) MFPA 1984).
Restriction
However, where jurisdiction is based on the ground that either or both of the parties had a
beneficial interest in a dwelling-house in England and Wales which was at some time during
the marriage used as a matrimonial home, (ie domicile and/or habitual residence are not
established) then the orders which the court can make are restricted, by section 20, to:

Lump sums orders not exceeding the value of the other party‟s interest in that
dwelling house

Property adjustment orders in respect of that dwelling house
What factors does the court take into account?
The court will take into account

“all the circumstances of the case, first consideration being given to the welfare while
a minor of any child”(section 18 (2))
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
Where an order has been made overseas “the extent to which that order has been
complied with or is likely to be complied with” (section 18 (6))
Otherwise the court will exercise its discretion having regard to the same statutory factors
contained in the Matrimonial Causes Act 1973 as would apply on an English divorce: “ the
section 25 factors”:“(a) the income, earning capacity, property and other financial resources
which each of the parties to the marriage has or is likely to have in the
foreseeable future, including in the case of earning capacity any increase in
that capacity which it would in the opinion of the court be reasonable to expect
a party to the marriage to take steps to acquire;
(b) the financial needs, obligations and responsibilities which each of the
parties to the marriage has or is likely to have in the foreseeable future;
(c) the standard of living enjoyed by the family before the breakdown of the
marriage;
(d) the age of each party to the marriage and the duration of the marriage;
(e) any physical or mental disability of either of the parties to the marriage;
(f) the contributions which each of the parties has made or is likely in the
foreseeable future to make to the welfare of the family, including any
contribution by looking after the home or caring for the family;
(g) the conduct of each of the parties[, whatever the nature of the conduct and
whether it occurred during the marriage or after the separation of the parties
or (as the case may be) dissolution or annulment of the marriage], if that
conduct is such that it would in the opinion of the court be inequitable to
disregard it;
(h) in the case of proceedings for divorce or nullity of marriage, the value to
each of the parties to the marriage of any benefit (for example, a pension)
which, by reason of the dissolution or annulment of the marriage, that party
will lose the chance of acquiring.”
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Agbaje
The facts of Agbaje were as follows.
Mr and Mrs Akinnoye-Agbaje were both Nigerian. Mr Agbaje (aged 71) and Mrs Agbaje
(aged 68) had met in England in December 1965 and married there, the following year, in
1967. Mr Agbaje was in England in order to study for the Bar, Mrs Agbaje was in England
to study and work.
Following the marriage, they lived in London. They had 5 children all of whom were born in
London and 4 of whom were educated in England. In 1972, they acquired British citizenship
and both had dual British and Nigerian nationality.
In 1973, Mr Agbaje returned to Nigeria to set up a legal practice. He was joined by Mrs
Agbaje and the children, the following year in 1974.
They lived at various address but eventually at a property at 2, Tin Can Island in Lagos,
owned by Mr Agbaje. In 1975, 2 of the children were brought back to England to be
educated and Mr Agbaje bought a house in London as a base when visiting London.
However, apart from visits in 1967/7 when Mr Agbaje came to London for surgery and other
studies, the family‟s home was in Nigeria.
Following the parties‟ separation in 1999, the wife came to live in the English property and
continued to live there.
In 2002, Mr Agbaje bought a second property in London with the intention, he said, of
passing this on to the youngest child.
In 2003, Mr Agbaje instigated divorce proceedings in Nigeria. The assets then totalled about
£700,000: being property in Nigeria worth £170,000 and the two properties in London worth
£530,000. Mr Agbaje earned £43,000 a year and Mrs Agbaje earned about £600 a year.
The Nigerian divorce
On 2nd June 2005, Nicol-Clay J granted the decree nisi of divorce in the Nigerian proceedings
and ordered
(a) 2 Tin Can Island, worth about £83,000 (19.7 million naira) to be settled on Mrs
Agbaje for life; and
(b) A lump sum of £21,000 (5 million naira) as “maintenance for life”.
As to 2 Tin Can Island, the judge made the order pursuant to Section 72(1) of the Nigerian
Matrimonial Causes Act 1990, which gives the court power to make a settlement of property
but not an outright transfer.
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As to the lump sum, Mrs Agbaje had sought a lump sum of 10 million naira (£42,000) which
her own lawyers had said would not be “bare existence” but would enable her to “ensure the
queen treatment that her husband got her used to”
The English Part III award
The wife was then granted permission to seek relief under Part III in the English court. The
judge at first instance Coleridge J commented
“The husband says that this is no more or less than a second bite of the cherry, that the
application must fail because there have been proceedings already in Nigeria. The wife
accepts in a sense that it is a second bite of the cherry but that she is entitled to succeed
because in the Nigerian proceedings she was afforded only the merest of nibbles and cannot
live here on what she has”
Coleridge J awarded Mrs Agbaje
(a) £50,000 to supplement her income needs; and
(b) £225,000 to meet her housing needs in London, she undertaking to relinquish her life
interest in 2 Tin Can Island
This amounted to a total award of £275,000 equivalent to 39% of the total assets.
While the Court of Appeal set aside this order, the Supreme Court restored it.
Agbaje: the proper approach
The Supreme Court in the case of Agbaje clarified the proper approach to be adopted in
relation to the exercise of the court‟s discretion in Part II applications.






The purpose of Part III is to alleviate the adverse consequences of no, or no adequate,
financial provision being made by a foreign court where there were substantial
connections with England (para 71)
The intention of Part III is not to „top-up‟ an overseas award so as to bring it in line
with what the applicant might have received if there had been an English divorce.
(para 65)
It would never be appropriate for the award under Part III to exceed the amount that
might have been awarded on an English divorce (para 73)
Wherever possible the court should provide for the reasonable needs of the parties
(para 73)
This does not mean that the English court should restrict itself to the minimum
required to overcome injustice (para 73)
Hardship, injustice or exceptionality are not preconditions for an award (paras 61 and
72)
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Post Agbaje cases
There have been a number of reported cases on Part III since Agbaje, including the
following:1.
Schofield v Schofield [2011] EWCA Civ 174
The case involved a German wife and her English husband, a soldier who held a British
Army pension. The parties married, lived and divorced in Germany. The capital assets were
divided equally; however, the German court declined jurisdiction to deal with the British
Army pension. It also implied an expectation that the pension would be dealt with in
England.
The wife was initially refused permission to bring a claim under Part III in the English court.
This was not based on any objections as to jurisdiction, but was founded on the judge‟s
interpretation of Agbaje (namely, that there should be 50% or more chance that the Applicant
will receive a substantial order for the „substantial ground‟ requirement in s. 13 MFPA 1984
to be met). However, the Court of Appeal disagreed with the judge‟s interpretation.
Furthermore, in terms of public policy, the Court of Appeal commented on the need for
international collaboration in this area: the German court had in this case implicitly looked to
the English court to make provision in relation to the English pension.
In practice, Part III is a useful tool for implementing an agreement or overseas order
following an overseas divorce in relation to an English pension. Parties can apply by consent
under Part III to obtain from the English court an order “sharing” the English pension,
effectively mirroring the overseas order.
2.
Golubovich v Golubovich [2011] EWCA Civ 479
This case involved a very wealthy Russian couple.
They married in 2007 and separated after 18 months. It was alleged that during their 18
month marriage they had spent over £2 million.
Following a Russian divorce, the wife applied for leave under Part III which she was granted.
The husband appealed both the grant of leave and the refusal to adjourn, on the basis that it
had given him only 24 hours to prepare his disclosure. The Court of Appeal dismissed the
husband‟s appeal on the ground that, on a pragmatic basis, the wife‟s earlier application for
financial relief had already been postponed by several months and the husband had already
repeatedly failed to engage in the English proceedings.
3.
M v M [2011] EWHC 2817 (Fam)
This case also involved a very wealthy Russian couple.
It was a 20 year marriage. Following a Russian divorce the wife applied under Part III.
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The husband refused to permit the wife to return to the matrimonial home, a property in
London worth about £4 million. This was notwithstanding that the property was empty as he
had purchased another substantial property where he was living.
The wife applied for interim maintenance. The husband failed to provide proper disclosure
or to engage properly in the proceedings.
The court awarded the wife maintenance of £460,000 a year, of which £150,000 was
specifically to meet her rental needs. The Judge held that when considering an application
for the interim maintenance under Section 14:
i.
no order for interim maintenance can be made until leave has been granted;
ii.
jurisdiction must be founded on domicile or habitual residence (not the dwelling
house ground);
iii.
the applicant must be in “immediate need of financial assistance”.
In assessing what was “immediate need of financial assistance” in relation to an application
for interim maintenance, “immediate” should be construed to mean “current” not “urgent”.
4.
Z v A [2012] EWHC 1434 (Fam)
In this case the parties had been married for 4½ years and had one child, aged 4.
The wife was worth £7 million (derived from her family‟s fortune). The husband was worth
£34 million.
The wife had a connection to England but neither the husband nor the marriage did. Only 15
months of the marriage had been spent in London. The husband had no assets in England;
the wife owned a flat in Knightsbridge.
Coleridge J. categorised this as a needs case. He awarded a lump sum of £3 million to
include £2 million to meet the wife‟s housing needs and £1 million being capitalised
maintenance, plus £50,000 a year for child maintenance.
© Rhiannon Lewis April 2013
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Appendix: Recognition of overseas divorces (with thanks to Richard Kwan, Dawson
Cornwell)
Determining whether a divorce is recognisable can be a complex exercise; the starting point
is the Family Law Act 1986. Part II deals with the Recognition of Foreign Divorces and
applies only to „overseas‟ divorces and not „transnational‟ ones. A „transnational‟ divorce
refers to a divorce where an important step has occurred in the UK – for example, where a
Talaq is pronounced in England but concluded in Pakistan. The case law is not clear cut but
it is suggested in the head-note to Berkovits v Grinberg (Attorney-General Intervening)
[1995] 1 FLR 477 that:
“where an important step in the proceedings leading to the divorce had taken place
in [the UK]… rather than in the jurisdiction in which the divorce was pronounced,
that divorce was properly to be regarded not as an overseas divorce but rather as a
transnational divorce.”
A transnational divorce must, unlike an overseas divorce, comply with English law. For an
overseas divorce to be recognised, much depends on whether the divorce was obtained via
„proceedings‟ or by means other than via „proceedings‟. „Proceedings‟ encapsulate „Judicial
and other proceedings‟.1 However, the interpretation of these terms by case law has been
murky and it is not always clear when a divorce will be taken to have been obtained via
proceedings.
What is clear is that a bare Talaq pronounced in front of witnesses, whose only role is to
witness the divorce, will not be considered as a proceedings divorce. 3 On the other hand, a
requirement to officially register the divorce would suggest that it was obtained via
proceedings (although such a requirement is not absolutely necessary).4 It seems that, for a
proceedings divorce, there must be the involvement of some kind of State recognised
machinery (which may be a religious body). Its role must be more than simply probative 5
although it need not have a power of veto (as the English courts have, but rarely exercise).
Section 46 of FLA 1986 explores the various grounds of recognition for each case:
46 Grounds for recognition
(1) The validity of an overseas divorce, annulment or legal separation obtained by
means of proceedings shall be recognised if—
(a) the divorce, annulment or legal separation is effective under the law of the
country in which it was obtained; and
(b) at the relevant date either party to the marriage—
3
4
5
Chaudhary v Chaudhary [1984] 3 All ER 1017
H v S [2011] EWHC B23 (Fam)
Chaudhary v Chaudhary [1984] 3 All ER 1017
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(i) was habitually resident in the country in which the divorce, annulment
or legal separation was obtained; or
(ii) was domiciled in that country; or
(iii) was a national of that country.
(2) The validity of an overseas divorce, annulment or legal separation obtained
otherwise than by means of proceedings shall be recognised if—
(a) the divorce, annulment or legal separation is effective under the law of the
country in which it was obtained;
(b) at the relevant date—
(i) each party to the marriage was domiciled in that country; or
(ii) either party to the marriage was domiciled in that country and the
other party was domiciled in a country under whose law the divorce,
annulment or legal separation is recognised as valid; and
(c) neither party to the marriage was habitually resident in the United
Kingdom throughout the period of one year immediately preceding that date.
(3) In this section “the relevant date” means—
(a) in the case of an overseas divorce, annulment or legal separation obtained
by means of proceedings, the date of the commencement of the proceedings;
(b) in the case of an overseas divorce, annulment or legal separation obtained
otherwise than by means of proceedings, the date on which it was obtained.
(4) Where in the case of an overseas annulment, the relevant date fell after the
death of either party to the marriage, any reference in subsection (1) or (2) above
to that date shall be construed in relation to that party as a reference to the date
of death.
(5) For the purpose of this section, a party to a marriage shall be treated as
domiciled in a country if he was domiciled in that country either according to the
law of that country in family matters or according to the law of the part of the
United Kingdom in which the question of recognition arises.
It is important to note that even if these conditions are satisfied, a court still has a discretion
to refuse recognition of the overseas divorce. Where a divorce has been obtained by means
of proceedings, the divorce may be refused if a party to the marriage was not given adequate
notice or a proper chance to take part in the proceedings (s. 51(3)(a) FLA 1986). Where a
divorce was obtained otherwise than by means of proceedings, the divorce may be refused if
there is no official document certifying that the divorce is effective in the country is was
obtained or no official document certifying that the divorce is effective in another country
where either party was domiciled (s. 51(3)(b) FLA 1986 There is also a public policy
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exception in s. 51(3)(c) FLA 1986, although it should be noted that judges are inclined to
respect decisions made abroad in the interests of international comity. 6
A declaration as to the parties‟ marital status may be obtained if necessary (s. 55 FLA 1986).
For such applications, he Attorney-General will need to be given notice and may decide to
take part in the proceedings.
In the addition, the marriage itself must be capable of capable of recognition, or at the very
least, be a void marriage (Sharbatly v Shagroon [2002] EWCA Civ 1507).
6
H v H (Talaq divorce) [2007] EWHC 2945 (Fam)
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