TM v GL

TM v GL

Faith's welfare requires that she lives with her mother, with contact to father conditional on stable accommodation to ensure consistency and emotional security. A section 91(14) order is justified for 12 months to prevent further disruptive litigation and allow arrangements to settle. Father's conduct in pursuing the enforcement application was unreasonable and merits an indemnity costs order.

Parties
Applicant Father: TM; Respondent Mother: GL
Jurisdiction
England and Wales
Judgment Date
02 October 2026
Procedural Posture
Family Child Arrangements and Enforcement / Final Judgment
Outcome
Orders made as set out in summary; applications otherwise dismissed.
Legal Topics
Child Arrangements Order, Enforcement of Child Arrangements, Section 91(14) Orders, Costs in Family Proceedings
Family Law Child Arrangements Order Enforcement of Child Arrangements Section 91(14) Orders Costs in Family Proceedings

Case Brief

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Parties

TM

Applicant Father

GL

Respondent Mother

Procedural Posture

Family Child Arrangements and Enforcement / Final Judgment

Legal Issues

  1. 1 Whether to vary child arrangements order and determine with whom the child should live
  2. 2 Whether to make a joint lives with order
  3. 3 Whether to impose a section 91(14) order restricting further applications

Ratio Decidendi

Faith's welfare requires that she lives with her mother, with contact to father conditional on stable accommodation to ensure consistency and emotional security. A section 91(14) order is justified for 12 months to prevent further disruptive litigation and allow arrangements to settle. Father's conduct in pursuing the enforcement application was unreasonable and merits an indemnity costs order.

Court Disposition

Orders made as set out in summary; applications otherwise dismissed.

Orders

  • Faith to live with mother.
  • Father to have alternate weekend contact and holidays, conditional on stable accommodation; reduced contact if not met.