The Goddard-Watts litigation has been underway now for nearly a decade; its life prolonged by the inability of Mr Goddard-Watts to tell the truth. After two unsuccessful attempts by Mr Goddard-Watts, the case has been heard by the Court of Appeal on Mrs Goddard-Watts’ successful challenge from the judgment of Sir Jonathan Cohen (in which he applied the Kingdon principles to justify leaving an earlier award tainted by fraud largely undisturbed). It is the first time the court has considered the impact of fraud in financial remedy cases since the Supreme Court’s judgment in Sharland. In a wide-ranging judgment, the court considers the applicability of the Kingdon principles and characterises Mr Goddard-Watt’s frauds as a species of conduct.
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