TM v GL [2026] EWFC 24 (B) (02 February 2026)

TM v GL [2026] EWFC 24 (B) (02 February 2026)

Faith's welfare requires a sole 'lives with mother' order, with detailed contact arrangements for father conditional on stable accommodation. Both parties are subject to a 12-month section 91(14) order restricting further applications for child arrangements or enforcement, to allow the new regime to settle and protect Faith from further litigation. Mother's costs of the enforcement application are awarded on the indemnity basis due to father's unreasonable conduct in pursuing duplicative and misconceived enforcement proceedings.

Citation
[2026] EWFC 24 (B)
Parties
Applicant Father: TM; Respondent Mother: GL
Jurisdiction
England and Wales
Judgment Date
02 February 2026
Procedural Posture
Children Act 1989 Private Law Proceedings / Final Hearing on Submissions
Outcome
Application for variation of child arrangements order granted in part; sole 'lives with mother' order made; detailed contact regime for father subject to conditions; section 91(14) order made against both parties for 12 months; mother awarded costs of enforcement application on indemnity basis.
Legal Topics
Child Arrangements Order, Section 91(14) Orders, Enforcement of Orders, Costs in Family Proceedings
Family Law Child Arrangements Order Section 91(14) Orders Enforcement of Orders Costs in Family Proceedings

Case Brief

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Parties

TM

Applicant Father

GL

Respondent Mother

Procedural Posture

Children Act 1989 Private Law Proceedings / Final Hearing on Submissions

Legal Issues

  1. 1 Whether to vary existing child arrangements order regarding Faith's living and contact arrangements
  2. 2 Whether to make a joint 'lives with' order or sole 'lives with mother' order
  3. 3 Whether to impose a section 91(14) order restricting further applications

Ratio Decidendi

Faith's welfare requires a sole 'lives with mother' order, with detailed contact arrangements for father conditional on stable accommodation. Both parties are subject to a 12-month section 91(14) order restricting further applications for child arrangements or enforcement, to allow the new regime to settle and protect Faith from further litigation. Mother's costs of the enforcement application are awarded on the indemnity basis due to father's unreasonable conduct in pursuing duplicative and misconceived enforcement proceedings.

Court Disposition

Application for variation of child arrangements order granted in part; sole 'lives with mother' order made; detailed contact regime for father subject to conditions; section 91(14) order made against both parties for 12 months; mother awarded costs of enforcement application on indemnity basis.

Orders

  • Faith to live with mother; father to have contact as specified, conditional on stable accommodation.
  • Section 91(14) order: no application for lives with, spends time with, or enforcement orders by either party for 12 months without leave.