“…Thorpe LJ returned to the issue of litigation misconduct in Clark v Clark [1999] 2 FLR 498. I do not propose to summarise the facts of that case which Thorpe LJ described, at p. 509, as, “as baleful as any to be found in the family law reports”. He a…”
“…urt can undoubtedly reduce the award from reasonable requirements generously assessed to something less. Indeed, that is exactly what happened in Clark v Clark [1999] 2 FLR 498. It may be that, unless there is no alternative, a court should not reduce a party to a “predicament of real need” (see Radmacher v Granatino [2010] UKSC 42;…”