S v B & Anor [2026] EWFC 86 (B) (26 February 2026)

S v B & Anor [2026] EWFC 86 (B) (26 February 2026)

The court found no substantiated evidence of parental alienation, coercive control, or risk of harm from the father. The child's welfare required a gradual progression to shared care, with initial Live With Order for the mother and stepped increase in time with the father, including overnight contact. Therapy may continue outside school hours with information sharing. A section 91(14) order is justified to prevent unnecessary further litigation for 12 months. No Finding of Fact Hearing is necessary as allegations are unsubstantiated and not proportionate to the child's welfare needs.

Citation
[2026] EWFC 86 (B)
Parties
Applicant Father: S; Respondent Mother: B; Child (via Guardian): K (child)
Jurisdiction
England and Wales
Judgment Date
26 February 2026
Procedural Posture
Family Law Child Arrangements and Prohibited Steps Orders / Final Hearing and Judgment
Outcome
Orders made for stepped progression to shared care: initial Live With Order for mother, Spend Time With Order for father, progressing to Shared Lives With Order in 2027; Prohibited Steps Order regarding therapy only as to timing and information sharing; section 91(14) order restricting further litigation for 12 months.
Legal Topics
Child Arrangements Order, Prohibited Steps Order, Parental Responsibility, Domestic Abuse Allegations, Parental Alienation, Section 91(14) Orders, Therapy for Children, Safeguarding
Family Law Child Law Child Arrangements Order Prohibited Steps Order Parental Responsibility Domestic Abuse Allegations Parental Alienation Section 91(14) Orders +2 more

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Parties

S

Applicant Father

B

Respondent Mother

K (child)

Child (via Guardian)

Procedural Posture

Family Law Child Arrangements and Prohibited Steps Orders / Final Hearing and Judgment

Legal Issues

  1. 1 Whether a Shared Lives With Order or Live With Order is in the child's best interests
  2. 2 Whether a Prohibited Steps Order should be made regarding the child's therapy
  3. 3 Whether allegations of domestic abuse, coercive control, or parental alienation require a Finding of Fact Hearing

Ratio Decidendi

The court found no substantiated evidence of parental alienation, coercive control, or risk of harm from the father. The child's welfare required a gradual progression to shared care, with initial Live With Order for the mother and stepped increase in time with the father, including overnight contact. Therapy may continue outside school hours with information sharing. A section 91(14) order is justified to prevent unnecessary further litigation for 12 months. No Finding of Fact Hearing is necessary as allegations are unsubstantiated and not proportionate to the child's welfare needs.

Court Disposition

Orders made for stepped progression to shared care: initial Live With Order for mother, Spend Time With Order for father, progressing to Shared Lives With Order in 2027; Prohibited Steps Order regarding therapy only as to timing and information sharing; section 91(14) order restricting further litigation for 12 months.

Orders

  • Live With Order in favour of mother initially
  • Spend Time With Order for father with gradual progression to overnight contact