Matthew Fletcher, led by Christopher Hames KC, acted for the Respondent Father. Whilst the facts of this case are somewhat unusual, the principles applied to the issue of Article 13 Defences are well known. In this case, on the facts, the Article 13 Defences pleaded were not successful and did not meet the high threshold required to justify the exercise of discretion. Summary return was ordered following what the Court found was a harmful abduction by the paternal family.