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Not quite sure how reciprocity can be achieved in family law matters without crossing the government's own red lines regarding CJEU jurisdiction and the weight of CJEU decisions in domestic law. The best one could hope to achieve seems to be domestication (i.e. replication of EU instruments in national law) without retaining the existing reciprocal arrangements.

One way to get around the situation where a divorce petition has already been presented before another EU court could be to resurrect the forum non conveniens rule and allow anti-suit injunctions.

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