Issues under European Union Law
In the case study as has been stated and discussed herein with, the matter deals substantially with the issues and concerns of transferring the custody of a 7 years aged child named Amelie from England to Austria as a result of the mutual separation of her parents herein named and referred to as Rory Jenson and Mia Vincent. The material fact that needs to be concerned herein is that the parents of the girl are neither married nor are they into any civil relationship agreement. The period for which they lived together is ten years and thereafter, choose to get separated when Mia being the mother of the child chooses to enter into a marital relationship with an Austrian businessman named Oskar Konstantin. The paper shall be presented and structured in Issue, Law, Application, and Conclusion format. The major issues and the application therefore of the same id discussed and settled as under:
The major issues that can be framed in the given case are stated as follows:
- Whether the consent of Rory, the father of Amelie required for transferring the custody of the child from England to Austria as planned by her mother Mia?
- Is the consent of Amelie being the Minor relevant for transferring the custody of her living from England to Austria?
- Whether the non-marital relationship of Rory and Mia confer any legal rights upon the parties to the relation herein Rory, Mia, and Amelie being the child out of the non-wedded relation?
- Whether the concern of the girl herein the child of Rory and Mia being suffering from dyslexia is relevant and material as far as the transfer of custody from England to Austria is concerned?
- Whether the father of Rory shall be liable to maintain the child and ensure the safety of her rights even after his partner herein referred to as Mia entered into a Marital relationship with the Austrian Businessman Oskar Konstantin?
The issues so presented and framed in the above discussion shall be settled and disposed of in the light of European Union Family Law and the considerations, therefore. Family Law comes under the Jurisdiction of the competence of the European Union and therefore the union has framed regulations specifically dealing with the judicial cooperation in civil matters the matters connected with the Family concerns. The regulations and rules of the European Union with regards to Family matters only lie and are applicable in the cases of cross-border matrimonial matters.
The relevant regulations that shall be considered herein for framed issues are listed herein and the relevant provisions of the same are also dealt with considering the provisions and terms of the legislative rules and regulations. Regulation(EC) No. 2201/2003 shall be one of the essential regulations that shall be considered for deciding the issues relating to the matrimonial and parental rights and judgments, therefore. The primary aim and objective of the regulation as has been stated above are to aid international couples in resolving their matrimonial disputes involving more than one country, over their divorce and custody of the children.
The other major and relevant legislation operating within the European union Jurisdiction apart from the regulations of the Union is Children Act of 1989 which specifically and expressly deals with the rights of the Children as well as the Parental responsibilities which could not be waived off in any case and circumstances and in the case of any derogation or wilful abstinence from the obligations as has been given under the legislation, the penalties and sanctioning proceedings therefore. The relevant provisions which shall be considered crucial for determination of the child and parental issues are Sections 1, Section 2, Section 3, Section 4, Section 7, Section 12 and Section 13. These sections have been identified as being relevant for the consideration and settlement of the issues so structured above. Summing up the essential obligations and requirements of the provisions referred particularly being important in the legislation, it could be reasonably drawn and inferred that the Welfare of the Child shall be of paramount importance which shall be considered by the court and have paramount importance as far as the Conclusion of the issues and matters relating to the Child is concerned. Section 2(2) shall be considered most important herein for the purpose of determining the lawful custody and the parental obligation of the child. As mentioned in the particular provision of the act it mentions two situations, under initial one the parental obligation shall lie on mother in the event of the parents not married to each other which is the premise of this study and the parental obligation shall lie and fall upon the father only when he voluntarily chooses to acknowledge and recognize the child in reference to provisions contained herein. By Virtue of Clause 7 of Section 2 it could be held that where more than one person has parental obligation in regards to the child they can act alone without other in meeting or consent but only subject to the privileges and restrictions of the act which cannot be derogated with. Parental responsibility shall be discussed in reference to the meaning attached under Section 3 of the act. Section 7 deals with the power of the court to ask an officer of the service to report upon the matters crucial for the welfare of the child. By virtue of Section 12 of the Legislation the Court shall make necessary arrangements with respect to the child and direct the parental obligations accordingly. By Virtue of Section 13 the child could not be removed from the Jurisdiction of United Kingdom without the written consent of every person having parental obligation or with the leave of the court which shall be relevant herein.
Issue 1: Whether the consent of Rory, the father of Amelie required for transferring the custody of the child from England to Austria as planned by her mother Mia?
Regulations Relevant to Cross-border Matrimonial Issues
As far as the first is considered and concerned, a detailed assessment and evaluation of the rules as has been mentioned and discussed above it can fairly be settled that the concept of Cohabitation is not recognized in the United Kingdom and for the same reasons, the consent of Rory being the father of the child shall not be considered necessary on the part of Mia being the mother of the child to transfer the custody of the child from England to Austria. As far as the European Jurisdiction and the family law regulations of the European Union are considered and concerned, the same has been acknowledged and recognized as a mutual style of living for the couple not married to each other and living together. Although the fact is that the European Union has recognized the concept of Cohabitation but the application and implementation of the same for parental obligations and duties shall be dependent upon the will and discretion of the states under European Union jurisdiction and governance, therefore. Considering the specific facts of this case which deals with the jurisdiction of the United Kingdom, the concept of Cohabitation is not recognized in its entirety but a provision lies therefore which says that entering into a cohabitation agreement between the living couples shall elevate their rights but not to the extent of legally wedded couples.
It has been stated in the case and the facts specifically that no civil agreement or court order was taken as far as Cohabitation is considered and for these reasons no liability shall be upon the parents to take the consent of each other to maintain the child. The family court of the specific jurisdiction where the contention has been challenged shall be the principal authority to decide the lawful custody of the child as well as the requirements of the consent of Rory the husband to shift and transfer the custody of the child from England to Austria. The case as has been discussed in this context shall be considered a weak case from the legal perspective as the alleged parents and non-wedded couples failed to enter into any kind of agreement specifically a Cohabitation agreement, given the fact they have been living together without marrying for around ten years and having a seven-year daughter. Legal support and backing, in this case, shall not be afforded to the partners referred to as Rory and Mia for the major reason that the couples failed to enter into any kind of agreement for registering their relationship which has been duly recognized by the European Union under its family law regulations and rules.
The relationship of Rory and Mia, in this case, shall not be held to be justified as the relationship lacks any effective legal and statutory registration and backing, therefore. Considering the Regulation 2201/2003 it can be inferred and deduced that the European Union recognizes the concept of Cohabitation but the ultimate and final decision lies with the respective states considering the domestic laws on the same subjects and the reasonability of legislating new laws on similar subjects incorporating novel titles and concerns as in this case the element of Cohabitation.
Key Provisions of Children Act 1989
The issue of consent shall be decided upon by the Court, in this case, considering the common agreements of the parents but any legal enforcement cannot be made by any couple in the case of consent not being taken despite the fact of mutual acknowledgment of the child by both the couples.
Issue 2: Is the consent of Amelie being the Minor relevant for transferring the custody of her living from England to Austria?
The Consent of the Child shall be material and relevant as the choice depends upon the child whether she wishes to live with her father or her mother herein referred to as Rory and Mia respectively. The freedom of the child to choose the spouse with whom he or she prefers to live shall be acknowledged and recognized and no derogatory orders or actins shall be aggravated with, which may prejudice the living interests of the child herein Amelie. Considering the facts of the case, it can be inferred specifically that the child, in this case, wishes to live in England with Rory being the father and her grandmother and does not wish to transfer from the place of her present living to the place where her mother wishes to shift her to herein, from England to Austria. In the case of legal representation and any suit, the court of law shall mandatorily and necessarily consider the consent of the Child to decide the transfer of custody from England to Austria. This issue shall be decided upon considering the due consent and concurrence of the child and thereafter any decision in regards to the same issue.
Issue 3: Whether the non-marital relationship of Rory and Mia confer any legal rights upon the parties to the relation herein Rory, Mia, and Amelie being the child out of the non-wedded relation?
The rights in the above case shall be conferred based on the acknowledgment and recognition of the Member states herein, United Kingdom jurisdiction where the element and concept of Cohabitation are not recognized in its entirety and the same shall have legal support and backing only in the cases of registration under the established family laws of the concerned jurisdiction as in this case the legislation of United Kingdom government. As far as the case of Cohabitation is concerned, it has got acknowledged by the European Union but the effective implementation and governance of the same element have been left to the member states. The member states are not under any compulsion to recognize the same and so the legal rights of those under cohabitation differ from jurisdiction to jurisdiction depending upon the acknowledgment and acceptability of Cohabitation as a valid relationship between the couples catering under it. As far as the United Kingdom jurisdiction is concerned, a critical study of the parental laws and matrimonial laws of the state suggests that although cohabitation is not recognized in the state if the couples enter into a cohabitation or civil partnership agreement legal rights shall be fostered upon them not equally as that of the matrimonial relationships but at a much higher pedestal then being not recognized and acknowledged by the state or court of law. Considering the facts of the case it can be validly made out that, the express mention of statements that the couples were living in a cohabited relationship for ten years but they voluntary and wilfully abstained from entering into any kind of civil partnership and cohabitation agreement and ignored the due process of law for registering the cohabited relation and all the arrangements and separation therefore after sharing the relationship for ten years was mutual and verbal and no written or express contract with regards to the same was entered into between the couples.
Assessment of Cohabitation Concept and Parental Obligations
The non-marital relationship shall therefore in this case apply the rules and regulations of the European Union and would not provide any kind of legal entitlement to the couples therefore in the cases of any dispute. The fact that could be inferred from referring to the rule as has been discussed herein is that although, the parents would have no rights in regards to any property or maintenance the child they have shall have all the rights as being the lawful child of Rory and Mia and the express, wilful and bona fide acknowledgment of the same by the couples. This shall entitle the seven-year daughter herein named Amelie to all the rights and therefore, parental obligations shall fall upon the parents to take care of their child even after being separated and ensure the protection of all the child’s interests Amelie.
The fact that Mia and Rory mutually separated from each other and Mia entered into a Marital relationship with an Austrian Businessman named Oskar shall be relevant while dealing with and assessing the entitled and eligible rights of the child and the court shall consider the concern in accordance to the same. Addressing the issue as has been stated above, it can be reasonably and validly concluded that the partner rights, in this case, shall not be eligible to be recognized as between Rory and Mia are considered but the rights of the child outside of them shall be effectively and duly recognized irrespective of the fact whether cohabitation is recognized principle in the jurisdictions concerned herein or not.
Issue 4: Whether the concern of the girl herein the child of Rory and Mia being suffering from dyslexia is a relevant and material concern as far as the transfer of custody from England to Austria is concerned?
Considering the facts and circumstances of the case, this issue shall be decided in the light of what is beneficial for the child and the court shall decide the issue following the same. As far as the rights of the child are concerned irrespective of the fact that the child is born out of a non-marital relationship, the court shall not be disabled and disentitled from entering into the substance of the rights of the child and pass the orders favouring the interests of the child which does not prejudice the interests of the child. In this case, also the matter shall be entertained and decided by the honourable Family court having jurisdiction in the England Jurisdiction either Suo-motu or on the application of either of the parent specifically at the application of the father of the child Rory as he is not willing to transfer the custody of the child from England to Austria and considering the facts in detail, the child is also not willing to relocate from the jurisdictions mentioned in this context for the sole reasons of she preferring to live in England at the house of her father with her Grandmother.
The girl suffering from Dyslexia and undergoing effective treatment in England shall be a relevant and material concern as far as the transfer of the custody of the child from England to Austria is concerned. The court shall consider this matter and shall pass an order which supports the cause of the child and ensures protection of the interests of the child and approve or restrict the willing shift and transfer from the places herein stated following the health of the child. The fact that the child also does not prefers to re-locate with her mother and new father to Austria shall also be a material concern as far as the transferring the custody from England to Austria is concerned. Rory and Mia are free to live their life as they will without any kind of legal sanction and intervention, the major reason being the non-registration of their relationship which they share and are living under, the Cohabitation Agreement.
Issue 5: Whether the father of Rory shall be liable to maintain the child and ensure the safety of her rights even after his partner herein referred to as Mia entered into a Marital relationship with the Austrian Businessman Oskar Konstantin?
Jurisdiction of UK Family Court
This issue is the major issue that has been considered, evaluated, and discussed in the following context. Rory being wilfully and voluntary acknowledging his child and responsible for her primary upbringing together with Mia is enough for him to be burdened with the obligation and responsibility to maintain the child irrespective of the fact that his relation with Mia has been mutually severed off as Mia has entered into a marital relationship with Austrian Businessman Oskar Konstantin.
Conclusion
In reference to the rules and application of the same to the facts of the case study the conclusions that have been drawn with specific reference to the issues and material observations therefore have been:
- No legal entitlement, eligibility and acknowledgement of the rights of the couple due to failure to enter into any kind of cohabitation agreement.
- The rights of the child as have been duly acknowledged by the non-wedded couples shall be honoured with and no prejudice to her rights shall follow on the failure of her parents to enter into any relationship agreement.
- Consent of the child and the disability shall be the material observations in regards to which the transfer of the custody of the child shall be decided.
- No Maintenance rights shall flow upon Mia and no obligation therefore shall follow upon Rory.
In the case study as has been stated and discussed herein, the matter in issue deals with the imposition of customs duties upon the Alcoholic fruit drinks so imported in the Jurisdiction of France by a German manufacturing corporation and entity named, UberChoc. The matter in issue also deals with some of the material restrictions and limitations by the French State regarding the sale of Alcohol drinks and related beverages having the content of Alcohol usage. These concerns shall be decided in the light of the Treaty of Functioning of the European Union and the provisions related to the free trade of Goods and Services. The framing of issues, applicable rules and regulations, and applications therefore shall be structured and presented in Issue Rule Application and Conclusion format dealing with all the relevant and material issues and considering the possible consequences and outcome of the same. The paper has been underlined and presented as under:
The issues that shall be considered relevant and material to clarify the point of disputes and contentions of the manufacturing entity referred to as UberChoc being run by a sole proprietor named Gunther. The relevant issues are framed as under:
- Whether Gunther legally entitled to challenge the 20 Percent duty on alcoholic fruit drinks on the grounds of either Article 30 or Article 110 of the Treaty of Functioning of the European Union or not?
- Is Gunther entitled to challenge the requirement under the French Decree that all the alcoholic drinks shall be sold only on the licensed premises and not elsewhere as mandated and directed by the French Government?
The relevant treaty that shall be considered herein to analyse, assess, and settle the issues is the Treaty of Functioning of the European Union, and the relevant articles and provisions which shall be considered necessary and relevant herein to settle the issues so framed are Article number 30, Article 110 and Article 34.
Considering the contents and provisions of these articles, they deal with the Freedom of Trade and dealing in goods and services of the entity crossing border within the jurisdiction of the European Union and the imposition of taxes and duties, therefore. Article 30 of the Treaty deals with the restriction on the imposition of customs duties between the member states on any kind of import and export and any other charges having equivalent effects. This absolute restriction and provision also apply to any kind of custom duties of fiscal nature. Subsequent articles that shall be discussed herein for the settlement and disposal of issues are Article 34 and Article 110.
Article 34 of the Treaty deals with the provision for the restricting any kind of Quantitative restrictions upon the imports between the member states being managed and forming part of the European Union Jurisdiction. Article 110 deals with the provision that no member states shall impose any excessive internal taxation and duties upon the exporting member states and the charge shall be similar to that of domestic appropriation in the specific state. All these articles directly and indirectly deal with the aim and objective of facilitating ease of trade and liberalization therefore, between the member states of European Union. These are the major articles that shall be covered and applied herein for the purposes of deciding the issues so framed and the arguments contended.
Apart from these rules and articles certain other supplementing and supporting provisions shall also be closely viewed and scrutinized for the purposes of settlement of the issues in the most efficient and effective manner that supports the case of the parties and avoids any kind of prejudices against the interests of the parties to the dispute, herein the aggrieve manufacturing business corporation and to be the petitioner or applicant and the State of France being the aggressor or respondent.
Issue 1. Whether Gunther legally entitled to challenge the 20 Percent duty on alcoholic fruit drinks on the grounds of either Article 30 or Article 110 of the Treaty of Functioning of the European Union or not?
Considering the rule as has been discussed in the above paragraphs and relating the same with the case study which has been referred to herein, it can be inferred and validly deduced that the manufacturing entity shall have the right to challenge the imposition of custom duty by the French government upon the alcoholic fruit bear so exported from German but the legal entitlement and mandate can be fostered upon the French state. The reason which shall be attributable for the same is the governing code for facilitation of trade between the member states is a Treaty which does not have a strong legal backing and recognition as it’s the case with strict legislations having judicial activism and scrutiny. As far as the governing code in this case is concerned, it is a Treaty for ease of facilitation of business between the member states but the same cannot be forced upon the states as the discretion lies upon the state whether to adhere to the same directions and guidelines or digress from the laid provisions in the articles as has been referred to in the Treaty under discussion. Treaty is only a arrangement between the voluntary participating nations to bind themselves with the provisions so consented upon but the adherence to the same cannot be compelled upon a state as the state is free to consider its domestic stability and thereupon after internal deliberations choose the extent to which the provisions of treaty could be adhered to and complied with.
In this case the Articles on the base of which the chocolate manufacturing corporation herein referred to as UberChoc under Gunther chooses to rebut the directions so issued by the French government shall not be considered as effective as it would have been if the directions were so given under virtue of a legislation. As International Law is considered is a “Weak Law” the non-adherence and non-compliance of the terms of treaty could only state the actions of the state to be unethical and prejudicing the business and trade interests of the member states under the Union jurisdiction but nothing more than that could be the result therefore.
The fact as has been stated in the specific case study clearly states that the custom duty has been imposed upon the alcoholic fruit drinks and chocolates fuelled alcohol ranging from 2-5 Percent. The twenty percent duty which has been imposed upon the products of UberChoc is fixed as standard for all the products ranging in the similar category and therefore Article 34 of the treaty shall not hold good here neither any legal implication of the same could compel the state from withdrawing such restrictions and impositions. Adherence to the treaty shall be there but in the case, when the government considering internal situations of the state feels that it shall be necessary to digress from some non-material terms of treaty and impose some alterations the same cannot be challenged on the ground of intervention and therefore no compulsion to derogate any such direction shall arise at the point.
The limitations of the state in this case is reasonable and applies to all the entities and imported or exported alcoholic fruit drinks or any other kind of food containing some alcohol which cannot be said to derogate the trading interests and rights of any member state. Although the European Union is considered to have competence over certain matters which shall be followed and complied to by the member states but the independence, sovereign status and independence of the member government shall also be duly recognised and therefore a cohesion should be there for ensuring cooperation between the aims, objectives and purposes of the Union as well as consideration of internal circumstances by the member states and implementation of the policies and provisions of treaties in accordance to the same.
As far as application of Article 110 is concerned and the legal eligibility of the corporation to challenge the direction of the member state government is concerned, the same cannot be held to be valid in this case as the imposition of custom duty for the similar kind and nature of products is basis on equal standard and reasonable parameters and no excess internal charge or extra burden is bulked up upon the corporation being the exporter for the consumers of French jurisdiction. The restrictions and provisions of Article 110 has been duly honoured and complied with in this case by the government and no derogation to the same has been aggressed by the state therefore.
Although a contravention under Article 30 can be said in this very case as custom duty has been imposed between the trade dealings amongst the member states, but the imposition shall be considered reasonable as it has not been for any singly entity or corporation rather it has been a general order and direction of the government foe import and export of all the domestically produced or procured or externally procured alcoholic drinks and alcohol foods therefore. The adherence to the provisions of the treaty could be reasonably digressed from in the case any situation when the government of the member states reasonably prefer so and no legal sanction shall follow then.
Issue 2: Is Gunther entitled to challenge the requirement under the French Decree that all the alcoholic drinks shall be sold only on the licensed premises and not elsewhere as mandated and directed by the French Government?
Considering the subsequent issue which substantially deals with the right of Gunther being the proprietor of the chocolate manufacturing corporation, the concern that shall be settled herein is primarily the legal right of Gunther to challenge the requirement of French Decrees which simply impose certain absolute and blanket restrictions upon the sale of the alcoholic fruit drinks and therefore. The restriction and direction of the French government which strictly prescribes for the premises in which the drinks could be sold shall not be considered to be violative of any right of the other member states as intervening with their free right to trade. The states are under absolute liberty to decide upon the jurisdictions wherein and the manner in which the product is ought to be sold. In this case the requirement of license for selling the alcoholic products shall not be considered as derogative of any trade right of any member state and for the same reason the manufacturing entity is under no liberty to challenge to authorship, validity and legality of the French decree which makes it mandatory for the markets and shops to have compulsory license for being entitled to sell these products from their premises. This direction shall not be considered in any manner as violative of any article of the Treaty under discussion. Although the European Union can make under its competence certain other policies governing external actions of a member state but the internal management and administration of the State is not subject to the control and competence of the Union and the member states shall being sovereign shall be considered as eligible and entitled for framing of the policies and issuing directions which they prefer to be the best suited for the smooth facilitation, management of trade in their domestic and internal jurisdiction. In this case the direction issued by the government that the products and articles of UberChoc shall be only sold in the licensed premises of the state tends to manage the trading affairs within the state and differently charge and maintain the details for the inventory of the alcoholic drinks which ensures adequacy of maintenance of records of the same and avoids any kinds of prejudices and exploitation of the rights of any other business entity and corporation dealing in the same trade or similar businesses, the only difference between the same manufactured, processed locally and not imported from outside the member state.
Free Trade is the major and primary aim and one of the founding principles of the European Union and for the same purposes the Treaty was formed which aimed to grant some exclusive competence to union for ensuring maintenance of free trade and expansion therefor within the member states, but this shall not be inferred to mean that the member states are totally disentitled from framing such rules and regulations which govern their internal business corporations and procedures for dealing with certain specific articles, their sale and procurement therefore.
In this case as a result of the inherent autonomy of the member states the directions for selling the alcoholic drinks and alcohol food only within the licensed premises shall be construed as reasonable, legal and valid and therefore no violation or contravention of the same shall be inferred in this very case and the petitioner shall fail for challenging the directions of the government. No arbitrary and biased actions or conduct could be inferred by the actions of the government and therefore the same shall stand against the petitioner and the petitioner corporation if it prefers and choses to sale the product cross border within the French jurisdiction the directions of the government shall be adhered to and complied with and the same and no legal enforcement against the directions so issued and mandates so delivered shall stand.
Conclusion
Referring to the above rules and application of the same to the facts and circumstances of the case study both the issues have been settled and disposed off considering the critical assessment and evaluation of the facts of the case. It has been observed in lieu of the issues and contentions of the German chocolate manufacturing corporation that both the issues shall be decided against the petitioner and therefore no relief shall be provided therefore.
- In reference to the first issue, it can be drawn that as far as the domain of the European Union in regards to the issue is not under the purview of Exclusive competence and the Articles so contended to be derogated by the member states, shall not stand as against the member state herein the French government for the major reasons of the non-binding and non-legal effect of the same. The states shall be at liberty to decide their trade management and the European Union only could guide and promote free trade but not restrict the imposition of duties in the case of member states deeming it fit and stable in the interests of the State trade.
- In reference to the issue two, it can be drawn that making directions for the purposes of selling the liquor made food and fruit drinks only at licensed premises does not unreasonably intervene with the corporation trading rights and hence cannot be said to contravening any objects and aims of the treaty under discussion.
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‘Regulation 2003/2201 – Jurisdiction And The Recognition And Enforcement Of Judgments In Matrimonial Matters And The Matters Of Parental Responsibility – EU Monitor’ (Eumonitor.eu, 2022)
<https://www.eumonitor.eu/9353000/1/j9vvik7m1c3gyxp/vitgbgiengvw> accessed 9 April 2022
‘Treaty On The Functioning Of The European Union (TFEU) | Practical Law’ (Practical Law, 2022)
<https://uk.practicallaw.thomsonreuters.com/2-107-6192?transitionType=Default&contextData=(sc.Default)&firstPage=true#:~:text=One%20of%20the%20two%20main,Treaty%20establishing%20the%20European%20Community.> accessed 9 April 2022
Webpage (2022) <https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A12012E%2FTXT> accessed 9 April 2022
‘Consolidated Version Of The Treaty On The Functioning Of The European Union’ (Legislation.gov.uk, 2022)
<https://www.legislation.gov.uk/eut/teec/contents> accessed 9 April 2022
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