De Gafforj (Appeal – Hadkinson Order) [2018] EWCA Civ 2070
Judgment date: 20 September 2018
Related
WX v HX [2023] EWFC 279 (B)
Judgment date: 21 December 2023
https://caselaw.nationalarchives.gov.uk/ewfc/b/2023/279
Mr Recorder Day’s judgment in a case involving complex procedural history, intervenors, non-disclosure and a ‘fragile’ business valuation. Of note is Recorder Day’s inclusion of his earlier decision to refuse a Hadkinson order. Recorder
WJB v HJM [2024] EWFC 116 (B)
Judgment date: 15 February 2024
https://www.bailii.org/ew/cases/EWFC/OJ/2024/116.html
District Judge Ashworth. This was an application by W for a Hadkinson order preventing H from pursuing his application to vary an order for periodical payments made in 2017 (‘the order’). The order provided

Hadkinson Orders: the Need to Show Restraint
This article addresses ‘Hadkinson’ orders (Hadkinson v Hadkinson [1952] All ER 567), in light of several recent cases handed down over a short period of time, highlighting the potential limitations as to their availability, namely:
* Williams v Williams [2023] EWHC 3098 (Fam) – Moor J
* WX v HX [2023] EWFC 279
Read the journal


Financial Remedies Journal – 2025 Issue 2 | Summer
Related
WX v HX [2023] EWFC 279 (B)
Judgment date: 21 December 2023
https://caselaw.nationalarchives.gov.uk/ewfc/b/2023/279
Mr Recorder Day’s judgment in a case involving complex procedural history, intervenors, non-disclosure and a ‘fragile’ business valuation. Of note is Recorder Day’s inclusion of his earlier decision to refuse a Hadkinson order. Recorder
WJB v HJM [2024] EWFC 116 (B)
Judgment date: 15 February 2024
https://www.bailii.org/ew/cases/EWFC/OJ/2024/116.html
District Judge Ashworth. This was an application by W for a Hadkinson order preventing H from pursuing his application to vary an order for periodical payments made in 2017 (‘the order’). The order provided

Hadkinson Orders: the Need to Show Restraint
This article addresses ‘Hadkinson’ orders (Hadkinson v Hadkinson [1952] All ER 567), in light of several recent cases handed down over a short period of time, highlighting the potential limitations as to their availability, namely:
* Williams v Williams [2023] EWHC 3098 (Fam) – Moor J
* WX v HX [2023] EWFC 279
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