Re M (children) (fact-finding hearing: burden of proof) [2008] EWCA Civ 1261, [2008] All ER (D) 187 (Nov)
English v Emery Reimbold & Strick Ltd [2002] EWCA Civ 605, [2002] 3 All ER 385 applies to family cases. After a judge has given judgment, counsel have a positive duty to raise with the judge not just any alleged deficiency in his reasoning process but any genuine query or ambiguity which arises on the judgment.
