{"id":1327,"date":"2021-10-21T15:39:18","date_gmt":"2021-10-21T14:39:18","guid":{"rendered":"https:\/\/unit.law\/?p=1327"},"modified":"2021-10-21T15:39:18","modified_gmt":"2021-10-21T14:39:18","slug":"the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law","status":"publish","type":"post","link":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/","title":{"rendered":"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law?"},"content":{"rendered":"

Introduction<\/span>\u00a0<\/span><\/h1>\n

Consider this thought: A parent who lives in the United Kingdom has been separated from their child who is in another country. That country is what we may call a \u2018destabilised\u2019 country in so far as it has been affected by war, a country in which its political system has come apart and a power vacuum exists in which we have competing parties vying to rule the country. That kind of a situation has a profound effect on its infrastructure such as local government, policing,\u00a0healthcare\u00a0and the justice system.\u00a0Consider another obstacle for this parent: the child is habitually resident in that country and not the United Kingdom. In addition, that country is not a member of the Hague Convention 1996.\u00a0Are there any options available for this parent to have the child returned to their care?<\/span>\u00a0<\/span><\/p>\n

The Court of Appeal has touched on\u00a0what\u00a0continues to remain an interesting talking point in the field of\u00a0international law. The\u00a0judgment recently handed down in\u00a0<\/span>S (Children)(Inherent Jurisdiction: Setting aside Return Order)\u00a0<\/span><\/i><\/a>[2021] EWCA\u00a0Civ\u00a01223 has set the stage for the question of whether\u00a0we will see any developments on the\u00a0use of\u00a0the\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction.<\/span>\u00a0<\/span><\/p>\n

In this article, we will be exploring the factual background of this case as well as the decision made by the Court\u00a0in order to\u00a0see what we can take from this recent case as to whether we will see a development in the future for this area of law.<\/span>\u00a0<\/span><\/p>\n

Background<\/span>\u00a0<\/span><\/h2>\n

The parents have three children\u00a0who\u00a0were all born in England. The Mother was born in England and the\u00a0Father\u00a0was born in Tripoli in Libya. The parties met in England in 2007 and started a relationship and thereafter, had an Islamic marriage the following year. The Father was later granted British citizenship. In December 2017, the parties and the three children travelled to Turkey for the purpose of meeting paternal family on holiday and then travelled to Libya at the end of that month.<\/span>\u00a0<\/span><\/p>\n

The Court\u2019s\u00a0assessment\u00a0was that the parents had agreed to move with the children to live permanently in Libya. Two weeks later however, the\u00a0Mother\u00a0returned to the country for an appointment for a benefits claim. The Mother expected the youngest child, F, to join her however, it transpired that the\u00a0Father\u00a0had not been able to secure an exit visa and the Mother travelled alone. The Mother travelled between Libya and England on several occasions in 2018 and throughout the year, the children and the\u00a0Father\u00a0remained in Libya. The mother returned to England in September 2018 and had not returned to Libya since then;\u00a0she\u00a0has\u00a0had\u00a0only indirect contact\u00a0with the children since.<\/span>\u00a0<\/span><\/p>\n

The Mother started proceedings in the High Court in November 2018 seeking the summary return of the children to England on the\u00a0basis that the children had been \u2018forcibly\u2019 retained in Libya by the\u00a0Father.<\/span>\u00a0<\/span><\/p>\n

During the course of\u00a0the wardship proceedings, the Court had determined it was necessary to hold a finding of fact hearing to determine the issue of habitual residence of the children and whether or not the Court had jurisdiction to make orders in respect of the children. Her Honour\u00a0Judge Hillier, the presiding judge, gave judgment on 25<\/span>th<\/span>\u00a0October 2019 and held that the children\u2019s habitual residence was in Libya and therefore, dismissed the\u00a0Mother\u2019s\u00a0application.<\/span>\u00a0<\/span><\/p>\n

The Court, in that judgment, had noted that the Court had jurisdiction in relation to the jurisdiction by virtue of their nationality:\u00a0the inherent\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction. During the hearing, the legal representatives for the\u00a0Father\u00a0had pre-emptively opposed any suggestion that the Court should exercise the\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction. The Mother\u2019s legal representatives did not put forward any submissions\u00a0with regard to\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>and therefore, the Court was of the view that this issue did not need to be explored.<\/span>\u00a0<\/span><\/p>\n

The Mother was granted permission to appeal and by way of a supplemental application sought to rely on an additional ground that the Court should have explored whether it was appropriate to exercise the\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction. That application was refused.<\/span>\u00a0<\/span><\/p>\n

Following this refusal, the\u00a0Mother\u00a0made a fresh application in which she sought to have the order of HHJ Hillier set aside. The Mother relied upon PD12F Family Procedure Rules 2010 in which she submitted there was a fundamental change of circumstances. The evidence for this was an expert report provided, albeit not a Part 25 expert report but the Court considered the report anyway. That report provided a view as to the geopolitical situation taking place in Libya. The Mother,\u00a0in a separate\u00a0application, sought to rely upon the\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction. The Judge in the first instance, Mostyn J, refused the application and considered the application to be an abuse of process and relied upon the principle of\u00a0\u2018Henderson abuse\u2019 as outlined in the case of\u00a0<\/span>Henderson v Henderson\u00a0<\/span><\/i>(1843)\u00a0Hare 100. The Mother appealed the decision.<\/span>\u00a0<\/span><\/p>\n

What does\u00a0the Court\u00a0mean by\u00a0<\/span>Parens\u00a0Patriae jurisdiction<\/span><\/i>?<\/span>\u00a0<\/span><\/h2>\n

Parens\u00a0Patriae\u00a0<\/span><\/i>is a\u00a0latin\u00a0term for \u2018parent of the people\u2019 and is a\u00a0rarely used and antiquated doctrine\u00a0related to the High Court\u2019s inherent jurisdiction over children.\u00a0Its\u00a0origin can be traced to an old case of\u00a0<\/span>Hope v Hope\u00a0<\/span><\/i>(1854) 4 De GM & G 328. The original basis of this concept was essentially a social contract that the child owed allegiance to the Crown and in return the Crown had a protective or\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction over the child wherever he was,\u00a0even when they are abroad by virtue of their nationality.<\/span>\u00a0<\/span><\/p>\n

History\u00a0has shown\u00a0that the higher Courts have been extremely apprehensive of exercising such a vast power over children who are neither habitually resident nor present in this country\u00a0on the basis of\u00a0nationality.\u00a0The argument is a straight-forward one and it is that international law is always premised on the respect, understanding and cooperation between nations and therefore, exercising the\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction in such circumstances would undermine that relationship between nations.\u00a0For a Court to\u00a0say they have\u00a0jurisdiction of a child who is neither habitually resident\u00a0nor present in the\u00a0country simply because they are a national of that country\u00a0is a very bold claim that runs\u00a0counterintuitive to those values promoted by international law. Looking at this case in particular, the\u00a0Mother\u00a0would have sought to invoke the High Court\u2019s inherent jurisdiction to order the return of the children to England even against the\u00a0fact\u00a0that the children\u00a0are\u00a0habitually resident in Libya\u00a0and continue to live there.<\/span>\u00a0<\/span><\/p>\n

What was decided by the Court?<\/span>\u00a0<\/span><\/h2>\n

In terms of the Court\u2019s decision, the Court was not minded\u00a0to agree\u00a0with Mostyn J\u2019s view that the Mother\u2019s application amounted to\u00a0<\/span>Henderson\u00a0<\/span><\/i>abuse and\u00a0cautioned against the application\u00a0of that\u00a0principle in cases\u00a0concerning\u00a0children. The Court set out a very concise guide of the sufficient powers of case management contained in the Family Procedure Rules 2010 and s.91(14) Children Act 1989 to deal with any abuse of process. The Court was of the view that to import\u00a0<\/span>Henderson\u00a0<\/span><\/i>abuse into children\u2019s cases could open the floodgates for satellite litigation.<\/span>\u00a0<\/span><\/p>\n

The Court was of the view that the judgment was flawed in that it failed to give sufficient consideration to the\u00a0Mother\u2019s\u00a0independent application to exercise\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction on the basis that the reasons the Judge relied upon related to his analysis of the application to set aside the earlier order,\u00a0and that the question of\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>was not thoroughly explored.<\/span>\u00a0<\/span><\/p>\n

What can we take from this?<\/span>\u00a0<\/span><\/h2>\n

The Court has remitted this case back to the High Court to consider the\u00a0Mother\u2019s\u00a0application to invoke\u00a0the\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>jurisdiction.\u00a0It was hoped that we could have seen a little more discourse discussed on the issue of\u00a0<\/span>parens\u00a0patriae\u00a0<\/span><\/i>by the Court of Appeal in this case however, they took a view that clearly this question should be considered by\u00a0the High Court.\u00a0<\/span>\u00a0<\/span><\/p>\n

The case serves as an interesting talking point because\u00a0the subject of\u00a0<\/span>Parens\u00a0patriae\u00a0<\/span><\/i>poses a difficult debate:\u00a0should the Court exercise jurisdiction\u00a0and intervene over\u00a0the welfare of a child who is a British national but is habitually resident in another country which by all accounts is a dangerous environment to be in whether it be by\u00a0war,\u00a0disease\u00a0or some other national disaster?\u00a0<\/span>\u00a0<\/span><\/p>\n

Is such an intervention justified? It will be interesting to see whether the High Court considers there should be a shift in the role of the inherent jurisdiction and\u00a0whether such an intervention on the Court\u2019s part could be justified\u00a0therefore,\u00a0international\u00a0family\u00a0law\u00a0practitioners should keep a watchful eye over any developments in this case.\u00a0<\/span>\u00a0<\/span><\/p>

Written by Amjad Kadhim<\/a>, Pupil Barrister, Unit Chambers<\/p>\n","protected":false},"excerpt":{"rendered":"

Introduction\u00a0 Consider this thought: A parent who lives in the United Kingdom has been separated from their child who is in another country. That country is what we may call a \u2018destabilised\u2019 country in so far as it has been affected by war, a country in which its political system has come apart and a […]<\/p>\n","protected":false},"author":3,"featured_media":1332,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"inline_featured_image":false,"footnotes":"","_jetpack_memberships_contains_paid_content":false},"categories":[7],"tags":[],"acf":[],"yoast_head":"\nThe Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law? - Unit Chambers<\/title>\n<meta name=\"description\" content=\"In this article, Amjad explores the Parens Patriae jurisdiction and the factual background of Re S to\u00a0see whether we will see a development in the future for this area of law.\u00a0\" \/>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/\" \/>\n<meta property=\"og:locale\" content=\"en_GB\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law? - Unit Chambers\" \/>\n<meta property=\"og:description\" content=\"In this article, Amjad explores the Parens Patriae jurisdiction and the factual background of Re S to\u00a0see whether we will see a development in the future for this area of law.\u00a0\" \/>\n<meta property=\"og:url\" content=\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/\" \/>\n<meta property=\"og:site_name\" content=\"Unit Chambers\" \/>\n<meta property=\"article:published_time\" content=\"2021-10-21T14:39:18+00:00\" \/>\n<meta property=\"og:image\" content=\"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg\" \/>\n\t<meta property=\"og:image:width\" content=\"2560\" \/>\n\t<meta property=\"og:image:height\" content=\"1707\" \/>\n\t<meta property=\"og:image:type\" content=\"image\/jpeg\" \/>\n<meta name=\"author\" content=\"Liam\" \/>\n<meta name=\"twitter:card\" content=\"summary_large_image\" \/>\n<meta name=\"twitter:label1\" content=\"Written by\" \/>\n\t<meta name=\"twitter:data1\" content=\"Liam\" \/>\n\t<meta name=\"twitter:label2\" content=\"Estimated reading time\" \/>\n\t<meta name=\"twitter:data2\" content=\"7 minutes\" \/>\n<script type=\"application\/ld+json\" class=\"yoast-schema-graph\">{\"@context\":\"https:\/\/schema.org\",\"@graph\":[{\"@type\":\"WebPage\",\"@id\":\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/\",\"url\":\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/\",\"name\":\"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law? - Unit Chambers\",\"isPartOf\":{\"@id\":\"https:\/\/unit.law\/#website\"},\"primaryImageOfPage\":{\"@id\":\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#primaryimage\"},\"image\":{\"@id\":\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#primaryimage\"},\"thumbnailUrl\":\"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg\",\"datePublished\":\"2021-10-21T14:39:18+00:00\",\"dateModified\":\"2021-10-21T14:39:18+00:00\",\"author\":{\"@id\":\"https:\/\/unit.law\/#\/schema\/person\/a9f2ba4c3fafb5a1a4e801207da57966\"},\"description\":\"In this article, Amjad explores the Parens Patriae jurisdiction and the factual background of Re S to\u00a0see whether we will see a development in the future for this area of law.\u00a0\",\"breadcrumb\":{\"@id\":\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#breadcrumb\"},\"inLanguage\":\"en-GB\",\"potentialAction\":[{\"@type\":\"ReadAction\",\"target\":[\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/\"]}]},{\"@type\":\"ImageObject\",\"inLanguage\":\"en-GB\",\"@id\":\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#primaryimage\",\"url\":\"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg\",\"contentUrl\":\"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg\",\"width\":2560,\"height\":1707,\"caption\":\"The Parens Patriae jurisdiction\"},{\"@type\":\"BreadcrumbList\",\"@id\":\"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#breadcrumb\",\"itemListElement\":[{\"@type\":\"ListItem\",\"position\":1,\"name\":\"Home\",\"item\":\"https:\/\/unit.law\/\"},{\"@type\":\"ListItem\",\"position\":2,\"name\":\"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law?\"}]},{\"@type\":\"WebSite\",\"@id\":\"https:\/\/unit.law\/#website\",\"url\":\"https:\/\/unit.law\/\",\"name\":\"Unit Chambers\",\"description\":\"Specialists in family law, experts in business\",\"potentialAction\":[{\"@type\":\"SearchAction\",\"target\":{\"@type\":\"EntryPoint\",\"urlTemplate\":\"https:\/\/unit.law\/?s={search_term_string}\"},\"query-input\":\"required name=search_term_string\"}],\"inLanguage\":\"en-GB\"},{\"@type\":\"Person\",\"@id\":\"https:\/\/unit.law\/#\/schema\/person\/a9f2ba4c3fafb5a1a4e801207da57966\",\"name\":\"Liam\",\"image\":{\"@type\":\"ImageObject\",\"inLanguage\":\"en-GB\",\"@id\":\"https:\/\/unit.law\/#\/schema\/person\/image\/\",\"url\":\"https:\/\/secure.gravatar.com\/avatar\/1c32d1fd7bcf1548fb4f5639c3fb8fe3?s=96&d=mm&r=g\",\"contentUrl\":\"https:\/\/secure.gravatar.com\/avatar\/1c32d1fd7bcf1548fb4f5639c3fb8fe3?s=96&d=mm&r=g\",\"caption\":\"Liam\"}}]}<\/script>\n<!-- \/ Yoast SEO plugin. -->","yoast_head_json":{"title":"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law? - Unit Chambers","description":"In this article, Amjad explores the Parens Patriae jurisdiction and the factual background of Re S to\u00a0see whether we will see a development in the future for this area of law.\u00a0","robots":{"index":"index","follow":"follow","max-snippet":"max-snippet:-1","max-image-preview":"max-image-preview:large","max-video-preview":"max-video-preview:-1"},"canonical":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/","og_locale":"en_GB","og_type":"article","og_title":"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law? - Unit Chambers","og_description":"In this article, Amjad explores the Parens Patriae jurisdiction and the factual background of Re S to\u00a0see whether we will see a development in the future for this area of law.\u00a0","og_url":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/","og_site_name":"Unit Chambers","article_published_time":"2021-10-21T14:39:18+00:00","og_image":[{"width":2560,"height":1707,"url":"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg","type":"image\/jpeg"}],"author":"Liam","twitter_card":"summary_large_image","twitter_misc":{"Written by":"Liam","Estimated reading time":"7 minutes"},"schema":{"@context":"https:\/\/schema.org","@graph":[{"@type":"WebPage","@id":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/","url":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/","name":"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law? - Unit Chambers","isPartOf":{"@id":"https:\/\/unit.law\/#website"},"primaryImageOfPage":{"@id":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#primaryimage"},"image":{"@id":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#primaryimage"},"thumbnailUrl":"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg","datePublished":"2021-10-21T14:39:18+00:00","dateModified":"2021-10-21T14:39:18+00:00","author":{"@id":"https:\/\/unit.law\/#\/schema\/person\/a9f2ba4c3fafb5a1a4e801207da57966"},"description":"In this article, Amjad explores the Parens Patriae jurisdiction and the factual background of Re S to\u00a0see whether we will see a development in the future for this area of law.\u00a0","breadcrumb":{"@id":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#breadcrumb"},"inLanguage":"en-GB","potentialAction":[{"@type":"ReadAction","target":["https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/"]}]},{"@type":"ImageObject","inLanguage":"en-GB","@id":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#primaryimage","url":"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg","contentUrl":"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg","width":2560,"height":1707,"caption":"The Parens Patriae jurisdiction"},{"@type":"BreadcrumbList","@id":"https:\/\/unit.law\/the-parens-patriae-jurisdiction-and-re-s-is-there-still-a-role-for-the-high-courts-inherent-jurisdiction-in-international-law\/#breadcrumb","itemListElement":[{"@type":"ListItem","position":1,"name":"Home","item":"https:\/\/unit.law\/"},{"@type":"ListItem","position":2,"name":"The Parens Patriae jurisdiction and Re S: Is there still a role for the High Court\u2019s inherent jurisdiction in international law?"}]},{"@type":"WebSite","@id":"https:\/\/unit.law\/#website","url":"https:\/\/unit.law\/","name":"Unit Chambers","description":"Specialists in family law, experts in business","potentialAction":[{"@type":"SearchAction","target":{"@type":"EntryPoint","urlTemplate":"https:\/\/unit.law\/?s={search_term_string}"},"query-input":"required name=search_term_string"}],"inLanguage":"en-GB"},{"@type":"Person","@id":"https:\/\/unit.law\/#\/schema\/person\/a9f2ba4c3fafb5a1a4e801207da57966","name":"Liam","image":{"@type":"ImageObject","inLanguage":"en-GB","@id":"https:\/\/unit.law\/#\/schema\/person\/image\/","url":"https:\/\/secure.gravatar.com\/avatar\/1c32d1fd7bcf1548fb4f5639c3fb8fe3?s=96&d=mm&r=g","contentUrl":"https:\/\/secure.gravatar.com\/avatar\/1c32d1fd7bcf1548fb4f5639c3fb8fe3?s=96&d=mm&r=g","caption":"Liam"}}]}},"jetpack_sharing_enabled":true,"jetpack_featured_media_url":"https:\/\/unit.law\/app\/uploads\/2021\/10\/plane-2.jpg","_links":{"self":[{"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/posts\/1327"}],"collection":[{"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/comments?post=1327"}],"version-history":[{"count":3,"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/posts\/1327\/revisions"}],"predecessor-version":[{"id":1330,"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/posts\/1327\/revisions\/1330"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/media\/1332"}],"wp:attachment":[{"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/media?parent=1327"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/categories?post=1327"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/unit.law\/wp-json\/wp\/v2\/tags?post=1327"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}