L (Child), Re [2025] EWFC 178 (B) (10 June 2025)

L (Child), Re [2025] EWFC 178 (B) (10 June 2025)

Given the findings of domestic abuse against the father, the lack of trust between the parents, the child's young age, and the recommendations of CAFCASS, the welfare of the child is best served by a sole lives with order in favour of the mother, with structured and progressive contact to the father. The mother is permitted to apply for a Polish passport and travel to Poland with notice. A section 91(14) order is made barring the father from making further applications for four years without permission. The prohibited steps order preventing removal from the jurisdiction is discharged. The arrangements are structured to prioritise the child's stability, safety, and best interests.

Citation
[2025] EWFC 178 (B)
Parties
Applicant (f): D. A. L; Respondent (m): D. A. D
Jurisdiction
England and Wales
Judgment Date
10 June 2025
Procedural Posture
Private Law Children Act Proceedings / Final Hearing
Outcome
Sole lives with order to the mother; structured contact to the father; permission for mother to apply for Polish passport and travel to Poland; section 91(14) order against father for four years; prohibited steps order discharged.
Legal Topics
Child Arrangements Order, Prohibited Steps Order, Domestic Abuse, Section 91(14) Barring Order, Parental Responsibility, International Child Law
Family Law Child Arrangements Order Prohibited Steps Order Domestic Abuse Section 91(14) Barring Order Parental Responsibility International Child Law

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Parties

D. A. L

Applicant (f)

D. A. D

Respondent (m)

Procedural Posture

Private Law Children Act Proceedings / Final Hearing

Legal Issues

  1. 1 Whether a shared lives with order or sole lives with order is appropriate for the child
  2. 2 Whether a prohibited steps order preventing removal from jurisdiction is necessary
  3. 3 Whether the mother should be permitted to apply for a Polish passport for the child and travel to Poland

Ratio Decidendi

Given the findings of domestic abuse against the father, the lack of trust between the parents, the child's young age, and the recommendations of CAFCASS, the welfare of the child is best served by a sole lives with order in favour of the mother, with structured and progressive contact to the father. The mother is permitted to apply for a Polish passport and travel to Poland with notice. A section 91(14) order is made barring the father from making further applications for four years without permission. The prohibited steps order preventing removal from the jurisdiction is discharged. The arrangements are structured to prioritise the child's stability, safety, and best interests.

Court Disposition

Sole lives with order to the mother; structured contact to the father; permission for mother to apply for Polish passport and travel to Poland; section 91(14) order against father for four years; prohibited steps order discharged.

Orders

  • Child to live with mother; father to have contact as specified, progressing from one to two overnights per week as appropriate.
  • Mother permitted to enrol child in local nursery.