“…s the approach to inter-partes agreements discussed by the Court of Appeal in Rose v Rose [2002] EWCA Civ 208, [2002] 1 FLR 978 (‘Rose’), and Xydhias v Xydhias [1999] 2 All ER 386; [1999] 1 FLR 683 (‘Xydhias’) apply to agreements or purported agreements reached in proceedings brought under the 1980 Hague Convention?…”
“…In Xydhias v Xydhias [1999] 2 All ER 386, the Court of Appeal emphasised that, because section 33A was designed to allow consent orders to be considered on the papers, the duty of the court to conside…”