PIL instrument(s)
Brussels IIa
Case number and/or case name
Pauline Siew Phin Chai v Tan Sri Khoo Kay Peng [2014] EWHC 1519 (Fam)
Details of the court
England and Wales, First Instance
Articles referred to by the court
Brussels IIa
Article 3
Paragraph 1 SubParagraph a Indent 5
Date of the judgement
01 May 2014
Appeal history
None
CJEU's case law cited by the court
None
Summary
The parties married in Malaysia in 1970. They were very wealthy, having properties across the world. They had 5 children who were all adults. The issue of jurisdiction was central because it would have pre-determined the available financial remedies. The divorce proceedings were first initiated by the wife in England on 14th February 2013. A fresh application was made in early May 2014. After the first set of English proceedings had commenced in February 2013, parallel proceedings were initiated by the husband in Malaysia. The husband challenged the jurisdiction of the English courts. In this context, it was accepted that the wife was habitually resident in England since October 2012. Therefore, even if the English court could had had no jurisdiction over the first application, it was considered that the English court had jurisdiction over the second application. In his first judgment, dated 17th October 2014, Mr Justice Bodley held: “40 […]I reject the case made on behalf of the husband that the wife is estopped from pursuing her case on jurisdiction at this hearing. Absent some sensible and pragmatic compromise between the parties, it follows that the two jurisdictions may well find themselves exercising concurrent jurisdictions until one jurisdiction or the other recognises and gives effect to an earlier decision of the other. That will arise if the husband establishes jurisdiction in Malaysia, either by upholding the concept of ‘domicile of dependence’, or by showing the wife's domicile to be there as well as his, which proposition the wife denies. I recognise that a concurrent jurisdiction outcome would be most regrettable and, for want of a better word, invidious. But in situations like this, where neither party is prepared to step down, it is sometimes unavoidable, as is noted in de Dampierre above, page 107 at F per Lord Goff and in DGC v. SLC [2005] 3 HKC 293 at paragraphs 20 and 21. […]” [40]

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