G v G [No. 2] (Approved)

EX TEMPORE JUDGMENT of Mr. Justice Michael Twomey delivered on the 11 th day of February, 2026

      This is a follow up decision to the judgment which was delivered in G v G (Child abduction: consent; grave risk) [2026] IEHC 45 (the " Principal Judgment ") and this judgment should be read in conjunction with that judgment.

      This judgment relates to the form of undertakings to be given, once a decision has been made that a child should be returned from Ireland to another country, being the child's habitual residence pursuant to the Hague Convention.

      In this regard, the Court has been provided with undertakings which are being suggested by the mother (who unlawfully removed the child from the US to Ireland). The mother claims that these undertakings should be given by the father (who remains in the US). These undertakings are contained in a letter sent by the mother's solicitors to the father's solicitors after the Principal Judgment was delivered. In that letter, the mother states that nine separate undertakings ' were required' in order to give effect to the order of the Court to return the child to Kansas.

      These nine undertakings ranged from the father providing an undertaking to discharge the costs of the mother obtaining a further Green Card (after she let her previous Green Card lapse) to an undertaking that the father pay $35,000 for 'up to six months maintenance and/or financial support' . Indeed, one of undertakings, which was stated to be 'required' for the child to be returned to the country from where she was abducted, was an undertaking from the father that: