MA v WK [2025] EWFC 499 (Cusworth J), published earlier this month, concerned the question of the validity of religious marriage ceremonies.

QEB’s William Tyzack represented the Attorney General.

The case concerned three applications for declarations of marital status in relation to Nikkah ceremonies conducted in England. The Attorney General intervened on the question of whether the ceremonies were valid in English law, the issue being whether subsequent registration in Pakistan and resulting overseas recognition could give rise to validity in England.

In refusing the applications for declarations, Cusworth J agreed with the arguments advanced on behalf of the Attorney General in relation to the concept of lex loci celebrationis, and that registration is evidential and administrative but does not bear on solemnisation.

The court also considered the concept of the presumption of marriage, and agreed that it cannot operate where there is clear evidence of a failure to comply with the formalities required by the lex loci.
Separately, in DD v AF and others [2026] EWHC 247 (MacDonald J), Will appeared on behalf of the Secretary of State for Education in an application for the adoption of a child brought to the UK from Nigeria. The Department of Education, with overall responsibility for adoption policy and regulation, intervened to make submissions on the complex legal issues in relation to intercountry adoption where the country involved is subject to special restrictions under section 9(4) of the Children and Adoption Act 2006.

Full details of the cases can be found under the cases section: https://www.qeb.co.uk/resources/ma-v-wk-2025-ewfc-499/ (MA v WK [2025] EWFC 499) and https://www.qeb.co.uk/resources/dd-v-af-and-others-2026-ewhc-247/ (DD v AF and others [2026] EWHC 247).