header-logo header-logo

18 March 2026
Issue: 8154 / Categories: Legal News , Costs , Child law , Family
printer mail-detail

Bad behaviour must relate to proceedings, holds Court of Appeal

The Court of Appeal has unanimously dismissed a £385,000 costs order against a father, in a case that centred on what is required to meet the threshold of ‘reprehensible or unreasonable’ behaviour

In Pringle v Nervo [2026] EWCA Civ 266, the mother, Liv Nervo, an international DJ, was in a relationship with Matthew Pringle, head of Manuka Doctor and member of an ‘extremely wealthy family’ in New Zealand. While she was pregnant with their child (C), she discovered he already had a long-term partner and family. Lawyers were instructed over a three-year period but discussions became increasingly acrimonious and Nervo later applied for a fact-finding hearing, alleging ‘reproductive coercion and controlling behaviour including gas-lighting, love bombing, blame-shifting, future faking and financial abuse through excessive litigation’. The judge refused. Pringle later withdrew his application for parental responsibility and a child arrangement order, for reasons of poor mental health.

Usually the parties bear their own costs in these cases. However, the judge ordered Pringle to pay 75% of Nervo’s costs, on the basis of his conduct, including that he was motivated by a desire to protect his privacy and reputation, the lateness of his application to withdraw from proceedings, and failure to attend remote hearings.

However, Lady Justice King, delivering the main judgment last week, held the judge erred by considering only the father’s conduct rather than that of both parties, wrongly concluded a finding of unreasonable conduct was justified, and noted Pringle produced medical evidence for his failure to attend hearings.

King LJ said: ‘It is clear that the father's behaviour, quite understandably, remains a source of considerable bitterness and continuing distress to the mother.

‘An order for costs however relates only to the conduct of the parties in relation to the pre-proceedings and proceedings and not to the events, abusive or otherwise, which led to the conception of C.’

Issue: 8154 / Categories: Legal News , Costs , Child law , Family
printer mail-details

MOVERS & SHAKERS

WSP Solicitors—David Ashcroft & Jessica O’Shea

WSP Solicitors—David Ashcroft & Jessica O’Shea

Commercial property and child law teams expand with senior hires

Duxton Hill Chambers—Lucas Bastin KC & Joshua Hiew

Duxton Hill Chambers—Lucas Bastin KC & Joshua Hiew

Set expands London and Singapore offering with senior international disputes hires

Gilson Gray—Gregor Duthie & Stephen Forsyth

Gilson Gray—Gregor Duthie & Stephen Forsyth

Firm strengthens real estate and litigation teams with partner promotions

NEWS
Behind the profession’s polished exterior, lawyers are ‘internally drained rather than physically tired’, according to a stark assessment of burnout in legal practice
Five years after the Domestic Abuse Act 2021 came into force, concerns remain that the family courts continue to minimise allegations of abuse in child contact disputes
Uber has built a formidable strategy for insulating itself from liability for drivers’ conduct, but the legal terrain differs sharply between the US and England and Wales
The House of Lords (Hereditary Peers) Act 2026 marks a constitutional watershed by severing the centuries-old link between hereditary titles and automatic membership of the upper chamber
The Civil Justice Council’s review of Part III of the Solicitors Act 1974 could mark the end of what one commentator calls an ‘outdated’ and overly technical regime governing solicitor-client fee disputes
back-to-top-scroll