A Question of Sport

It is February 1990. Karen Richardson is 22 years old and working at a local optician. She meets her future husband, Ray Parlour, that year. Ray is 19 and signed his first professional contract with Arsenal less than 12 months ago.

Football, as culturally significant then as it is now, was about to change beyond all measure. On 17 July 1991 the 22 clubs that then made up the Football League First Division signed the Premier League Founders’ Agreement, signalling their joint notice of resignation from the Football League. The Premier League was born shortly thereafter.

Seismic changes would soon follow. Greg Dyke’s efforts to televise the new product on the BBC were blown out of the water by Rupert Murdoch’s BSkyB. They paid c. £304m to show 60 games a season.[[1]] With that, football in this country went from cultural staple to financial monolith.

The young Ray Parlour’s career dovetailed almost exactly with the foundation of the new league. He made his first start for Arsenal on 29 January 1992. It would be the last season of the old First Division in which Ray made six appearances. What followed was a career played out in the newly minted Premier League.

All of this came with Karen’s support. Readers may recall that in the Parlour divorce (McFarlane v McFarlane; Parlour v Parlour [2004] EWCA Civ 872, [2004] 2 FLR 893), Bennett J at first instance said this about one of Karen’s contributions to her husband’s career:[[2]]

‘As to the husband’s contribution he was and is a very talented footballer. That sprang from his natural talent, being a member of the Arsenal Football Club, and having the good fortune to be coached by Arsène Wenger, a top class coach. So, strictly speaking, the financial wealth of the family was created by the husband. However, in my judgment, there is a very significant factor in the success of the husband in which the wife played a vital role. The wife has suggested in her evidence that the husband was and is a drinker. From what I have read in the papers and been told by the husband and wife in evidence, I am satisfied that the husband was in an environment where, before the advent of Arsène Wenger in 1996, there was very considerable drinking amongst certain players in the Arsenal Football Club. In the early days I am satisfied that the husband did participate in some of those drinking sessions. However the wife realised that that was the way to ruin and unhappiness and I am satisfied that in about the mid 1990’s or slightly later she took a grip on the situation and encouraged and persuaded her husband to move away from that style of living. That rather bland description of what she did probably understates her contribution in this respect. In the mid 1990’s the husband gave interviews to the press in which he publicly praised the wife for all that she did to bring him back from the brink.’

Future planning

The money pouring into the nascent Premier League and the unusual financial dynamics it created for its young stars was apparent in the Parlour case. At the FDR, the parties had agreed that of c. £3m of capital, Karen would receive c. £1.12m, with the sole issue left for determination being her claims for periodical payments. The Judge found that Ray was earning, and would be earning, c. £1.2m per annum net until the expiry of his contract at the end of the 04/05 season. At first instance, global periodical payments were fixed at £250,000 p.a. on a joint lives basis. In the Court of Appeal, quantum was increased to c. £444,000 p.a. but with a 4-year extendable term.[[3]]

In circumstances where the Judge had assessed Karen and the children’s needs at £150,000 p.a., that decision seems curious, but Thorpe LJ explained the rationale thus:[[4]]

‘Mr Francis in his submissions was at pains to say that his client was approaching the end of his career at its present exalted height; he was prone to injury; his contract might not be renewed at its conclusion when he will be thirty-two years of age. These considerations only underline the obvious need for a substantial proportion of the income in the present fat years to be stored up against the future famine. Again I conclude that it would be wrong in principle to leave the responsibility and opportunity to the husband alone. The wife’s and the children’s needs were put at £150,000 by the judge. To award her the global figure of £444,000 per annum sought by Mr Mostyn allows her and obliges her to lay-up £294,000 per annum as a reserve against the discharge of her periodical payments order. I would in this case order a four-year extendable term. Hopefully a clean break will be achievable then on an assessment of the husband’s earning capacity at thirty-five years of age and the wife’s independent fortune derived from the original capital settlement augmented by the substantial annual surplus built into her periodical payments order in the interim.’

‘Stockpiling’ was born; a concept aimed at addressing the extreme oddities of an athlete’s career (particularly in the Premier League era).

In the period since Parlour, there have been a great many financial remedy cases involving athletes, specifically Premier League footballers, albeit disappointingly few have been reported.

The financial size of those claims has grown in tandem with the success of the league. Comparing the start of Mr Parlour’s career with its end (around the time of his divorce) and the present day is illustrative:[[5]]

Stockpiling would rear its head again some 12 years later in the case of AB v FC [2016] EWHC 3285 (Fam). The husband, then aged 27, was playing in a major European league, having spent the preceding period playing in the Premier League. His career was significantly promising that the spectre of a transfer ‘into football’s financial stratosphere’ was not out of the question. The parties had a child, aged just 22 months.

The striking fact of AB v FC, perhaps one depressingly common to athletes, was the stark contrast between the husband’s earnings (found by the late Roberts J to be c. €1.2m p.a. net) with his capital (before debts), which was limited to: c. £86,000 in a property in France, £95,000 in cash held following the sale of an investment property and a development in Miami with equity of £374,000 (which was extinguished by his obligation to fund the second instalment of the investment) – as the Judge put it: ‘Other than that, H has virtually nothing in terms of cash reserves or savings save for £85,470 (€100,000) which is due in respect of an outstanding contractual bonus payment’ (at [23]).

Endorsing the concept of stockpiling, Roberts J said this:

‘I am equally satisfied that, notwithstanding the absence of any marital acquest, this is a case where W’s substantial ongoing contributions to the welfare of the family should be reflected in an entitlement to the future security which she seeks both for herself and for A.’ (at [98])

And:

‘To that extent, it is not unreasonable, in my judgment, to allow W to “stockpile” a portion of the sums she receives in order to divert those sums towards the discharge of a mortgage liability. Notwithstanding the length of the marriage, she has many years of intensive child-rearing in front of her and she is entitled to find that contribution reflected in the award which this court makes for her at the conclusion of these proceedings.’ (at [99])

The Judge’s order provided for global maintenance at £204,000 p.a., the spousal portion of which was to endure on a joint lives basis, with £80,000 p.a. earmarked for mortgage repayments. A ‘review’ clause was included for 7 years’ time to coincide with the potential end of the husband’s playing career.

Of course, there is a flipside to such short, lucrative careers. In AB v FC, Mr Southgate QC (for the wife) suggested that, in the event of a career ending injury, ‘all bets are off’ (at [70]).

Futures cut short

One need only look to the Queen’s Bench Division to see quite how fragile these careers can be. In Collett v Smith & Anor [2008] EWHC 1962 (QB), Swift J DBE dealt with a personal injury claim brought by Benjamin Collett, a budding Manchester United footballer whose career was brought to an abrupt end at the age of 18 following a challenge by Mr Smith (the first defendant) in a reserve game against Middlesbrough.

Having heard evidence from the likes of Sir Alex Ferguson and Gary Neville as to Mr Collett’s ability, character and prospects, the Judge calculated his potential earnings across a career forecast at Premier League and Championship level at £4.534m total, that sum being discounted by 15% to factor in the risk of injury:

‘[139] I calculate the claimant’s loss of earnings as a professional footballer as follows:

At Championship level:	£3,261,055
At Premiership level:	£1,401,930
Less
Prospective earnings to age 35	£128,482
Total:	£4,534,503’

In the circumstances, Mr Collett could not possibly be described as ‘lucky’, but he must count in the small number of professional athletes who suffer an injury of such magnitude that results in a successful claim for compensation. There will be many who find a career cut short with no such remedy.

Privacy and the modern world

Enter Goodman v Walker [2024] EWFC 212 (B) (Walker), the high-profile proceedings involving one Kyle Walker (then playing right back for Manchester City and England) and Lauryn Goodman. There had been previous Schedule 1 litigation with respect to the parties’ first child, Kairo (aged 4). Ms Goodman brought proceedings for additional provision with respect to a further child, Kinara (aged 1).

Mr Walker had capital assets valued at c. £24m (at [22]). His income was assessed as lying ‘[in] the region of £7,000,000 to £10,000,000 per annum gross or approximately £3,500,000 to £5,000,000 per annum net’ (at [23]).

As a marker of just how significantly footballers’ salaries had ballooned in the period between the decisions of Parlour and Walker, the right back who played alongside Mr Parlour in the 2003/04 Arsenal ‘Invincibles’ side (known mononymously as ‘Lauren’) was reputed to earn £20,000 p.w. or £1.04m p.a. gross.[[6]]

Amongst a raft of other issues, HHJ Hess determined that Mr Walker was to pay Ms Goodman global child maintenance at £12,500 p.c.m. or £150,000 p.a. (CPI-linked). The Judge considered this to be a ‘generous’ sum (at [70]). Cristiano Ronaldo (centre forward for Al-Nassr in the Saudi Pro League) would nevertheless match this yearly figure every 6.5 hours (with his reported £200m annual salary).

Notable in the judgment of HHJ Hess was the discussion of anonymisation. Practitioners were spared an ‘MC v FC’:

‘I agree with what Ms McNeil-Walsh has said. It would be a nonsense, opening the court to ridicule, to try to redact or anonymise this judgment to prevent identification of the parties. Further, a perusal of the many hundreds of newspaper articles published about these matters clearly illustrates that the mother has not just cooperated with, but actively instigated, press coverage placing in the public domain her own children, the circumstances of their conceptions and what she thinks about the father. It sits ill for a person to come to court arguing for privacy for her children when, just a very short while earlier, she took a payment from the press to visit the European football championship with her son dressed in an England football shirt with the name “Daddy” on the back, and to be willingly photographed doing this to provide journalistic fodder which the newspapers were only too happy to use. If the children suffer any harm from the publicity of these matters, it has already happened, and it will largely be the result of the mother’s own decisions and actions. For me, on the facts of this case, the balancing exercise must come down against the mother’s argument. For me, the right of the press to scrutinise and comment upon the court’s procedures and decisions, and what the mother has requested of the father and how he has responded, are on this occasion a greater priority.’ (at [94])

More to life than men’s football?

Why has an article entitled ‘A Question of Sport’ focused entirely on men’s football? In short, because that (for the moment) is where the money is. There are only a very small number of European professional athletes competing in sports other than football who can generate significant wealth from their returns in the sporting arena.

Take tennis: whilst the highest (on court) men’s tennis players earned £15m in prize money in 2025, only eight players in the world could match the average Premier League salary of £4.16m p.a. None of them were British (Jack Draper was 10th in the ATP Money List).

And the women’s game? The highest paid footballer is thought to be Trinity Rodman of Washington Spirit, reported to earn approximately £1.5m p.a. It has some way to travel to match the riches of the men’s sport but wages are growing faster: Rodman’s salary is more than triple that of the highest-earning women’s player at the beginning of the decade (Sam Kerr, who was estimated to earn £400,000 p.a. from Chelsea in 2020). At that rate, perhaps it is just a matter of time until we see the first reported financial remedy decision in which a fortune has been generated in the Women’s Super League rather than the English Premier League?

Or, like much of public life, will yet more go private?

But will we even know when those cases come around? Perhaps the more likely result of the increased emphasis on transparency is fewer reported decisions and more prominent sports stars taking their family disputes in house via arbitration and other non-court dispute resolution models.

After all, there are few occasions where the interaction of a sports star with the law generates positive coverage. Immediate examples come to mind: the sentencing remarks of HHJ Deborah Taylor, the Recorder of Westminster, following Boris Becker’s bankruptcy, or, delving back even further, the coverage that followed Lester Piggott, 11-time champion jockey, when he similarly failed to pay his taxes. For sportspeople, there is certainly such a thing as bad publicity.

The fear must be that, even in an era of greater transparency, we are unlikely to see another Parlour case played out in full view. For the parties, perhaps that is a positive development, but for those of us curious to see how the court is to grapple with these unusual cases, it would be a shame.

[[1]]: It is of note that adjusted for inflation, Murdoch’s deal would be worth c. £850m today. That is dwarfed by the last domestic TV deals for the Premier League which were estimated to bring in £5bn in revenue https://www.bbc.co.uk/sport/football/67619756

[[2]]: J v J [2004] EWHC 53 (Fam).

[[3]]: A thought for the pressures of coping with work against the background of court proceedings: (1) on the Saturday (10 January 2004) prior to the Monday hearing before Bennett J, Ray came on in the 72nd minute of a 4–1 win against Middlesborough; and (2) on 9 May 2004, the day prior to the Court of Appeal hearing, Ray was booked by Mike Dean in the 84th minute at Craven Cottage. One way to relieve stress.

[[4]]: McFarlane v McFarlane; Parlour v Parlour [2004] EWCA Civ 872, [2004] 2 FLR 893 at [77].

[[5]]: https://www.capology.com/

[[6]]: https://www.the-independent.com/news/people/profiles/lauren-the-main-aim-is-the-champions-league-this-is-arsenal-s-year-487055.html

Notes

1 It is of note that adjusted for inflation, Murdoch’s deal would be worth c. £850m today. That is dwarfed by the last domestic TV deals for the Premier League which were estimated to bring in £5bn in revenue https://www.bbc.co.uk/sport/football/67619756

2 J v J [2004] EWHC 53 (Fam).

3 A thought for the pressures of coping with work against the background of court proceedings: (1) on the Saturday (10 January 2004) prior to the Monday hearing before Bennett J, Ray came on in the 72nd minute of a 4–1 win against Middlesborough; and (2) on 9 May 2004, the day prior to the Court of Appeal hearing, Ray was booked by Mike Dean in the 84th minute at Craven Cottage. One way to relieve stress.

4 McFarlane v McFarlane; Parlour v Parlour [2004] EWCA Civ 872, [2004] 2 FLR 893 at [77].

5 https://www.capology.com/

6 https://www.the-independent.com/news/people/profiles/lauren-the-main-aim-is-the-champions-league-this-is-arsenal-s-year-487055.html

This is an article from the forthcoming Financial Remedies Journal 2026 Issue 1.