In Hamilton v Hamilton [2013] EWCA CIV13 the Court of Appeal was asked to decide on whether it was appropriate to vary the terms of a Consent Order which provided for payment of a lump sum by a former wife to her former husband.

The Order required the wife to pay her husband £450,000 in 5 payments.

The wife paid a total of £240,000 by which time her business had been placed in administration and she was unable to make any further payments.