Discovering Financial Assets: Goddard-Watts v Goddard-Watts \[2023\] EWCA Civ 115 ================================================================================= This [case](https://www.bailii.org/ew/cases/EWCA/Civ/2023/115.html)presented the courts approach in dealing with the discovery of a party concealing true financial assets after the division of the assets by way of a Consent Order. Mr and Mrs Goddard-Watts began living together in 1987, married in 1996, and had three sons. They divorced in 2010, agreeing on the division of family assets in a consent order. Under this agreement, the husband retained his business interest while the wife kept the family home. However, it was later revealed that the husband had not disclosed certain trust assets, which the court determined in 2015 to be a material non-disclosure, leading to the order being set aside. The court reassessed the case and awarded the wife additional funds to account for this non-disclosure. Yet again, the husband failed to disclose crucial information regarding the potential sale of his business, which resulted in a share sale worth £25 million and a potential further £75 million. Consequently, the second award was also set aside in 2020, and a new hearing was scheduled in 2022 to determine a fair division of the assets. At the 2022 hearing, the judge adhered to the limited approach set forth in [*Kingdon v Kingdon*](https://vardags.com/law-guide/how-the-courts-decide-a-financial-settlement/kingdon-v-kingdon-non-disclosure-in-divorce). This meant that he focused exclusively on the non-disclosed assets, leaving the rest of the award unchanged. Consequently, he granted an additional award based on the wife's needs without reassessing the entire settlement. However, Mrs Goddard-Watts appealed this decision, and the Court of Appeal sided with her. The court found that in cases of non-disclosure, it has the flexibility to tailor its approach to the specifics of each case, which might sometimes include following the ['Kingdon Approach'](https://vardags.com/law-guide/how-the-courts-decide-a-financial-settlement/kingdon-v-kingdon-non-disclosure-in-divorce). Nevertheless, it was noted that the 'Kingdon Approach' was inappropriate here because the case couldn't be confined to a single issue. For instance, Mrs. Goddard-Watts had made significant contributions to the family's welfare and supported the children, who were estranged from their father. The Court concluded that the fraudulent non-disclosure in this case was so extensive that it required a comprehensive reassessment of the financial settlement, starting from a clean slate. Vardags' team of top divorce lawyers delivers a bespoke legal service to HNW and UHNW individuals, their families, and businesses. We are the only family law firm with an in-house Financial Forensics department. Our team specialises in identifying, tracing, valuing, and forensically reviewing assets, including businesses, property, and investments. If you are a high-net-worth individual going through or considering a divorce, it is crucial to have an accurate valuation of all your spouse's assets. Whether these assets are held in complex international trusts, hidden within investment portfolios, or concealed through intricate share structures, they must be identified and considered for a fair settlement. **If you're considering or going through a divorce and suspect that your spouse is not fully disclosing his or her financial situation, we can help. Click below for a free initial consultation with one of our expert divorce solicitors.** [BOOK FREE CONSULTATION](https://vardags.com/contact "BOOK FREE CONSULTATION") About Us -------- Ayesha VardagFounder & President "A DIVORCE LAWYER WIDELY REGARDED AS ONE OF THE WORLD'S BEST" The Metro Vardags offer a unique approach to the law, specially tailored to the needs of HNW individuals. We offer City-quality representation for your divorce and family law needs. Our lawyers come from the very best universities and receive the very best training - they are determined, diligent, and dedicated to getting the best outcome... [read more](https://vardags.com/about-us) [BOOK FREE CONSULTATION](https://vardags.com/contact) Related Reads ------------- ### Four ways non-disclosers hide their assets Non-disclosure in divorce cases has recently hit the headlines again with reports of asset hiding... [READ MORE](https://vardags.com/family-law/four-ways-non-disclosers-hide-their-assets "Four ways non-disclosers hide their assets") ### Three ways to overcome non-disclosure I have lost count of the number of times that a client has said to me "my spouse is very clever,... [READ MORE](https://vardags.com/family-law/three-ways-to-overcome-non-disclosure "Three ways to overcome non-disclosure") Related Guides -------------- [Financial Non-Disclosure in Divorce](https://vardags.com/law-guide/how-the-courts-decide-a-financial-settlement/financial-non-disclosure-in-divorce "Financial Non-Disclosure in Divorce") [Gohil v Gohil & Sharland v Sharland](https://vardags.com/law-guide/important-divorce-cases/gohil-v-gohil-sharland-v-sharland "Gohil v Gohil & Sharland v Sharland") [Kingdon v Kingdon: Non-Disclosure in Divorce](https://vardags.com/law-guide/how-the-courts-decide-a-financial-settlement/kingdon-v-kingdon-non-disclosure-in-divorce "Kingdon v Kingdon: Non-Disclosure in Divorce") [How Courts Use Financial Forensics in Divorce](https://vardags.com/law-guide/how-the-courts-decide-a-financial-settlement/using-financial-forensics-guide-to-disclosure "How Courts Use Financial Forensics in Divorce") [Asset Tracing in Divorce](https://vardags.com/law-guide/how-the-courts-decide-a-financial-settlement/asset-tracing-in-divorce "Asset Tracing in Divorce") [What Is Financial Disclosure in Divorce?](https://vardags.com/law-guide/how-the-courts-decide-a-financial-settlement/what-is-financial-disclosure-in-divorce "What Is Financial Disclosure in Divorce?") [Young v Young](https://vardags.com/law-guide/important-divorce-cases/young-v-young "Young v Young") [How do you uncover hidden assets during divorce proceedings?](https://vardags.com/faq/divorce/how-to-uncover-hidden-assets-during-divorce-proceedings "How do you uncover hidden assets during divorce proceedings?") [My spouse is hiding assets in offshore bank accounts and companies, what can I do?](https://vardags.com/faq/divorce/spouse-hiding-assets-offshore "My spouse is hiding assets in offshore bank accounts and companies, what can I do?") Glossary Reference ------------------ ### Consent order An order sealed by the court setting out an agreement by the parties. The information on this website is intended as a guide and does not constitute legal advice. Vardags do not accept liability for any errors in the information on this website, nor any losses stemming from reliance upon the statements made herein. 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