Hamilton v Hamilton [2013] EWCA Civ 13; [2013] WLR (D) 26
“An order in ancillary relief proceedings for the payment of a series of lump sums over time was not necessarily an order for a lump sum by instalments, within section 23(3)(c) of the Matrimonial Causes Act 1973, and therefore variable under section 31 of the 1973 Act.”
WLR Daily, 24th January 2013
Source: www.iclr.co.uk