“…and a judge is only entitled to make findings that go beyond those sought in the document if they are within the “known parameters” of the case: Re W (A Child) [2016] EWCA Civ 1140; [2017] 1 WLR 2415, Re L (Fact-finding Hearing: Fairness) [2022] EWCA Civ 169. If a court is considering making findings that go beyond those parameters, the p…”
“…Re W (A Child) [2016] EWCA Civ 1140; [2017] 1 WLR 2415 concerned unexpected findings against professional witnesses, as to which MacFarlane LJ said this:…”
“…The principle in the George Wimpey case was applied on an appeal from an order in care proceedings in Re W (A Child)(Care Proceedings: Non-PartyAppeal) [2016] EWCA Civ 1140 [2017] 1 WLR 2415. In that case, the judge at first instance made findings that a social worker and a police officer had lied to the court about their investig…”
“…The obligation to put relevant matters in cross-examination has been stated in a number of authorities from Browne v Dunn [1894] 6 R 67 (HL) to Re W (A child) [2016] EWCA Civ 1140, at [88-89]. Still more recently, the Privy Council considered the matter in Chen v Ng [2017] UKPC 27, where the Board’s judgment, given by Lords Neuberger and…”