Claire Mireille N’Djosse v Ifedayo Adedapo Kolawole Adeyeye

In family proceedings concerning an abducted child, the court may permit identification of the parties and child where publicity serves a sufficiently important protective or public-interest purpose. The court must balance the child’s and family’s privacy rights under European Convention on Human Rights art 8 against freedom of expression and the public interest in reporting under art 10. Where those interests substantially coincide, publication may be authorised. The court may also make disclosure orders directed at locating a person whose custody is important to securing compliance with orders for a child’s return.

The proceedings concerned Laurys, a four-year-old child born and habitually resident in France. His father abducted him during contact, taking him through England to Nigeria, where the child remained under guardianship arrangements made without the mother’s knowledge and on a false basis.

The High Court had previously exercised its exceptional inherent jurisdiction, made Laurys a ward of court and ordered his return to France: [2025] EWHC 1548 (Fam). The Court of Appeal considered that order correct and refused permission to appeal. The father subsequently breached the return order, received custodial sentences, and was mistakenly released from prison. The issues at this hearing were whether the parties and child should be identified publicly and whether disclosure orders should be made to assist in locating the father.

1. Identification of the parties and child. The usual anonymity afforded in Family Division proceedings required reconsideration. The court balanced the child’s and family’s privacy under art 8 of the European Convention on Human Rights against freedom of expression and the public interest in reporting under art 10.
2. The balance was not difficult on the facts. Publicity might assist in securing the father’s return to custody, which was regarded as the best, and perhaps only, prospect of reunification between the child and his mother. The interests protected by arts 8 and 10 therefore coincided. The court permitted publication of the names and images of the father and child, and publication of the mother’s name.
3. The court further recognised a public interest in transparent reporting where the State had failed to prevent or promptly remedy the father’s mistaken release from custody.
4. Disclosure. Disclosure orders were made to facilitate investigation of the father’s whereabouts. The judgment was sent directly to the Governor of HMP Pentonville for immediate transmission to the Chief Constable of the Metropolitan Police.

1. High Court (Family Division): The court previously made Laurys a ward of court and ordered his return directly to France under its inherent jurisdiction in [2025] EWHC 1548 (Fam).
2. Court of Appeal: The Court of Appeal considered the return order correct and refused permission to appeal.
3. High Court (Family Division): The present judgment permitted publication of the parties’ names and images of the father and child, and made disclosure orders.