FAQ on The Current Effectiveness of Pre-Nuptial Agreements

FAQ - The Current effectiveness of Pre-nuptialgive legal status to the prenuptial agreement, but
agreementsthe marriage itself took place in the jurisdiction of
How are Prenuptial agreements perceived by theEngland and Wales. The parties entered into a
courts?prenuptial agreement which specified similar terms
 Historically in England and Wales, Prenuptialto that of the one in Crossley v Crossley (above)
agreements have been claimed ‘to be notwith the exception that the contract specifically
worth the paper they’re written on’.provided that any assets or income accrued by
They have remained as an anomaly between theeither throughout the course of the marriage,
UK and the USA’s perception on matrimonialwould remain owned by that party. The husband
law. Whilst they are recognised in the USA, andwas shown a draft of the agreement a week
indeed are constantly the highlight of infamousprior to the wedding, and did not seek legal advice
celebrity break ups, they are not perceived withand there was no disclosure of any of the
the same enamour in England and Wales.Wife’s assets.
However, the stance of the courts is slowly After their marriage in November 2008, the
beginning to align with that of their Americancouple went on to have two children and the
counterparts. In recent case law, prenuptialhusband subsequently left his lucrative job in the
agreements have been recognised, and givenfinancial sector, and began to study in the field of
substantial weight in determining the outcome ofbiotechnology, with the intent to return to the
ancillary relief. Although still not considered to befinancial sector at a later date. He claimed that he
binding, the presence of one is regarded awould continue contributing to the household
significant factor under Section 25 of theexpenses, but by March 2005, his savings were
Matrimonial Causes Act 1973. With the added factcompletely depleted, and he requested that his
that prenuptial agreements are binding in many ofwife solely provide for the household expenses
our EU neighbouring states, and that more peopleuntil he finished his studies. Eventually, in August
from the EU are seeking permanent residence in2005 the couple separated and in July 2007 the
the UK, it seems logical that to give uniformity todecree absolute was pronounced. The Husband
the laws of Europe and legally acknowledge thesought to ignore the terms of the prenuptial
prenuptial.agreement, and sought to claim from his
 If a prenuptial agreement is not binding,Wife’s assets. However, it was argued by the
what’s the point in having one?wife that to do this would contravene her rights
 The significance of a prenuptial agreement hasunder Article 1 of the European Convention of
been made none so more apparent than in theHuman Rights, and that beyond maintenance, the
recent decisions of Crossley v Crossley [2007]Husband should not be entitled to any further sum
EWCA Civ 1491 and Radmacher, formerlyof money and that removal of any of her
Granatino v Granatino Sub nom NGv KRproperty in the form of a lump sum or otherwise
(prenuptial contract) [2009] EWCA Civ 649.would constitute improper interference with he
In the former case of Crossley, the terms of theproperty rights, as protected under the article.
prenuptial agreement were fully complied with inThis was held by the courts, and her property
ancillary relief proceedings, and it was one of thewas protected from any further claims against it.
first instances in the England and Wales jurisdictionHowever, this did not mean that the Wife was
that the courts fully recognised the importance offree from providing any ancillary relief, and an
the agreement. However, as prevalent of thisorder was made for her to provide £5.56M in
case was in promoting the status of thetotal maintenance to her Husband and to
prenuptial agreement from influential to binding,accommodate his proprietary needs in both the
the courts were able to hide behind the excuse,UK and Germany, when caring for the Children of
the even without the agreement, a similar resultthe relationship. On top of this, the Wife was
would have been achieved. Mr and Mrs Crossleyordered to pay a further £70, 000 a year to
had been married a little over a year, bothmeet the needs and costs of their children.
bringing substantial wealth into the marriage,However, this order was determinable on her
although Mr Crossley had significantly more. Theychildren reaching majority and completing their full
had both entered into a prenuptial agreementtime education.
which stated that both parties would leave the But in the Gratino case, the spouse still had to
marriage with whatever assets they brought withpay maintenance- why was that?
them into it. In their relationship, they bore no It is true that the spouse still had to pay
children, and on the irretrievable breakdown ofmaintenance, but a prenuptial agreement can not
their marriage, Mrs Crossley sought to have therestrict or prevent maintenance orders. They are
terms of the prenuptial set aside. The courtsthere to protect a persons assets that they
identified that this ploy was simply such that Mrspossessed or acquired before or during the
Crossley could exploit the state of English law tomarriage. The most intriguing thing about this
obtain a portion of Mr Crossley’s wealth. Also,case, is that the Wife’s assets remained hers,
given the fact that there were no dependants ofand the Husband was not entitled to any of her
the marriage, and it had been for such a shortestate, as agreed in the prenuptial agreement.
amount of time, it made logical sense to upholdThe fact that the European Convention of Human
the terms of the prenuptial.Rights was highlighted also shows the significance
However, more recently, the prenuptialof the UK being part of the EU. Although the
agreement has been given a recognition that itEnglish and Wales jurisdiction does not recognise
has never before received in the history ofprenuptial agreements as a legal document, to set
Matrimonial law in the English jurisdiction. In theit aside without consideration would be a breach
case of Grantino v Grantino also known as NG vof EU law, and in particular, a breach of Article 1
KR (prenuptial contract) a Husband from Franceof the first protocol of the convention.
had entered into a prenuptial agreement with his So prenuptial agreements are they still not
Wife from Germany. Both countries jurisdictionslegally binding?