Legal History in the Making: Gohil v Gohil & Ors [2025] EWHC 3646 (Fam)

Mr and Mrs Gohil lived a settled and comfortable life up until their separation in the early 2000s. They managed to agree a consent order in 2004, which provided a lump sum of £270,000 to Mrs Gohil together with periodical payments for her and the children.

Preparing a consent order is a relatively straightforward process if you are able to seek appropriate legal advice. However, Mrs Gohil was concerned that her husband had not provided full and frank financial disclosure at the time. The family had enjoyed an extravagant lifestyle which did not fit the disclosed income of Mr Gohil.

Why is full and frank financial disclosure important?

The Gohil case is one of the most significant family law cases involving financial disclosure following divorce. It highlights the importance of honesty during financial remedy proceedings and demonstrates how the courts can intervene where assets, income, or other financial resources have not been properly disclosed.

When parties negotiate a financial settlement, both individuals are under a continuing duty to provide full and frank financial disclosure. This obligation allows the court to assess the true extent of the matrimonial assets and determine whether a proposed consent order is fair. This forms part of the wider process of financial provision.

Financial disclosure commonly includes information relating to:

• Property ownership
• Savings and investments
• Business interests
• Pensions
• Employment income
• Self-employed earnings
• Overseas assets
• Trust interests and other financial resources

Where relevant information is withheld, the court may later conclude that the original settlement was based upon an incomplete financial picture.

In 2007, Mrs Gohil applied to set aside the 2004 order due to the material non-disclosure of Mr Gohil’s assets. There was an extensive criminal investigation against him for fraud and money laundering which he was convicted of in 2011. A confiscation order (Proceedings of Crime Act 2002) was made against him for £28 million. There were several rounds of proceedings and appeals from both sides which were heard in both the Court of Appeal and the Supreme Court.

Additional resource: Divorce & Finances: Frequently Asked Questions

Can a consent order be set aside because of hidden assets?

Yes. Although consent orders are intended to provide finality following divorce, the Family Court can revisit a financial settlement in certain circumstances. One of the most common reasons is where a party has failed to provide full and frank disclosure and hidden assets are subsequently discovered.

The court may consider factors such as:

• Whether assets were deliberately concealed
• The value of any undisclosed wealth
• The effect of the non-disclosure on the original settlement
• Whether the conduct amounted to fraud or financial misconduct
• Whether a different order would likely have been made had the true position been known

The Gohil litigation became a leading example of how the courts approach allegations of asset concealment and dishonest disclosure during financial remedy proceedings.

In 2025, the High Court was once again considering Mrs Gohil’s claim. There was extensive evidence and multiple respondents. Due to Mr Gohil’s criminal activity, the Crown Prosecution Service was an intervenor to the proceedings (a third party not part of the original legal dispute who then joins the proceedings because they have a direct interest). Williams J had to consider which of Mr Gohil’s assets were tainted through his criminal activity and which assets were untainted and could be made available to Mrs Gohil. The court identified Mr Gohil’s conduct to be so grave and selfish that it impacted Mrs Gohil’s earnings. This contributed to Mrs Gohil being awarded £6.833 million.

What does the Gohil case mean for divorcing couples?

The decision reinforces the principle that parties should not benefit from the concealment of matrimonial wealth. It also confirms that the courts are willing to take a robust approach where there is evidence of non-disclosure, misleading financial information, or attempts to hide assets from a spouse.

For individuals involved in divorce proceedings, the case provides an important reminder that financial settlements should be based on accurate information. Where concerns arise regarding hidden property, undisclosed investments, business assets, offshore accounts, or other financial resources, specialist legal advice should be sought as soon as possible.

Key lessons from the Gohil case

The lengthy litigation highlights several important principles that apply to many financial remedy cases:

• Financial disclosure must be complete and accurate
• Consent orders rely on honest information being provided by both parties
• Hidden assets can significantly affect a financial settlement
• The court has powers to set aside orders in appropriate circumstances
• Financial misconduct can have lasting consequences
• Early legal advice can help protect your financial position

Although every case will depend on its individual facts, the decision demonstrates that the courts place considerable importance on transparency, fairness, and compliance with disclosure obligations.

Speak to a family law solicitor

Every family situation is unique. Questions surrounding finances, property, pensions, businesses, and arrangements for children can often be complex.

Obtaining legal advice at an early stage can help you understand your options, and ensure that any agreements reached are legally sound.

To discuss your situation in confidence, please contact one of our matrimonial law specialists at GoodLaw Solicitors LLP.

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