Internal Abduction

Re R (child) [2016] EWCA Civ 1016.
The Court of Appeal have said that the test in relation to internal abduction is purely a paramount welfare test. They do acknowledge that the approach set out in Re J (A Child) (Custody Rights: Jurisdiction) [2006] 1 AC 80 may be of some utility. That being so it may be argued that a starting point for a judge hearing an application for the return of a child 'abducted' within England could be that an immediate return would be in the child's welfare interests.
The Court of Appeal declined the invitation to formally adopt the Re J starting point in internal abductions.