A Child Born 2017, Re (Final Hearing) [2026] EWFC 55 (B) (27 February 2026)

A Child Born 2017, Re (Final Hearing) [2026] EWFC 55 (B) (27 February 2026)

The father's failure to address or evidence abstinence from substance misuse, lack of insight or responsibility for domestic abuse, and non-compliance with court orders present significant and ongoing risks to the child. The welfare checklist and professional evidence support no direct or indirect contact except for limited indirect contact by photographs. A section 91(14) order is necessary to protect the child and mother from further harmful litigation for five years.

Citation
[2026] EWFC 55 (B)
Parties
Applicant (father): LZL; Respondent (mother): VQD
Jurisdiction
England and Wales
Judgment Date
27 February 2026
Procedural Posture
Children Act 1989 Child Arrangements/contact / Final Hearing
Outcome
Application for direct contact dismissed; limited indirect contact ordered; section 91(14) order made for five years.
Legal Topics
Child Contact, Domestic Abuse, Substance Misuse, Section 91(14) Children Act 1989, Welfare Checklist, Parental Responsibility, Indirect Contact, Enforcement of Contact Orders
Family Law Child Contact Domestic Abuse Substance Misuse Section 91(14) Children Act 1989 Welfare Checklist Parental Responsibility Indirect Contact +1 more

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Parties

LZL

Applicant (father)

VQD

Respondent (mother)

Procedural Posture

Children Act 1989 Child Arrangements/contact / Final Hearing

Legal Issues

  1. 1 Whether direct or indirect contact between the father and child should be ordered
  2. 2 Whether a section 91(14) order restricting further applications should be made
  3. 3 Assessment of risk to the child from the father's domestic abuse and substance misuse

Ratio Decidendi

The father's failure to address or evidence abstinence from substance misuse, lack of insight or responsibility for domestic abuse, and non-compliance with court orders present significant and ongoing risks to the child. The welfare checklist and professional evidence support no direct or indirect contact except for limited indirect contact by photographs. A section 91(14) order is necessary to protect the child and mother from further harmful litigation for five years.

Court Disposition

Application for direct contact dismissed; limited indirect contact ordered; section 91(14) order made for five years.

Orders

  • No direct or indirect contact between father and child except for photographs to be sent by mother to father at least once every nine months, with conditions on dissemination.
  • Father prohibited from making further Children Act applications regarding the child for five years without permission of a District Judge (section 91(14) order).