Sapna is a family law barrister of over 15 years’ experience specialising in aspects of
private children law and financial relief. Sapna combines her deep knowledge of the
law with a key ability to get to the root of problems in any dispute, particularly those
involving financial relief.
Here Sapna gives an update on problems with conduct in financial relief
proceedings, which courts are increasingly concerned with. She begins by outlining
the statutory framework and highlighting relevant case law. She gives critical advice
on when it is best (or not best) to plead conduct. She explains how where injustice is
measurable, the court is prepared to act.

Key Words/Topics
Conduct
MCA 1973
Jones v Jones
Miller
McFarlane
Gross Personal Misconduct
Dissipation/add-backs
Litigation misconduct (costs)
Adverse inferences (non-disclosure)
Tsetkov V Khayrova [2023] EWFC 130
Two Stage Test: Threshold and causation
NV J [2024]
Domestic Abuse
LPV MP [2025]
Serious wrongdoing
Quantifiable financial impact
40% reduction in sharing claim
Exceptional facts
Careful judicial reasoning
MRUV ECR (Financial Remedies) [2025] EWFC 219 (B)
Needs based adjustment
YV Z [2025] EWFC 221

Clear financial loss
Proportionate evidence