E (A Child), Re (Complex Fact-Finding: Allegations of Domestic Abuse and Alienating Behaviours) [2025] EWFC 422 (16 April 2025)

E (A Child), Re (Complex Fact-Finding: Allegations of Domestic Abuse and Alienating Behaviours) [2025] EWFC 422 (16 April 2025)

The court found that while some of the mother's allegations of emotional and physical abuse by the father were established on the balance of probabilities, the most serious allegations of sexual abuse and rape were not proven. The court found the father engaged in emotionally abusive and inappropriate behaviour towards the children, including verbal belittling and physical chastisement, but did not find evidence of sexual abuse or grooming. The court found the mother had, at times, engaged in behaviour that undermined the father's relationship with the children but did not find a pattern of deliberate alienation. The findings inform future welfare decisions for E.

Citation
[2025] EWFC 422
Parties
Applicant/respondent: Mother; Applicant/respondent: Father; Subject Child: E (A Child)
Jurisdiction
England and Wales
Judgment Date
16 April 2025
Procedural Posture
Private Law Children Proceedings (fact Finding) / Fact Finding Judgment Following Multi Day Hearing
Outcome
Findings of fact made; mixed findings against both parents; no findings of sexual abuse or rape; findings of emotional and some physical abuse by the father; findings of some undermining behaviour by the mother but not deliberate alienation.
Legal Topics
Domestic Abuse, Coercive and Controlling Behaviour, Parental Alienation, Child Arrangements, Fact Finding Hearings
Family Law Child Law Domestic Abuse Coercive and Controlling Behaviour Parental Alienation Child Arrangements Fact Finding Hearings

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Parties

Mother

Applicant/respondent

Father

Applicant/respondent

E (A Child)

Subject Child

Procedural Posture

Private Law Children Proceedings (fact Finding) / Fact Finding Judgment Following Multi Day Hearing

Legal Issues

  1. 1 Whether the father perpetrated sexual, physical, emotional, and coercive abuse against the mother and children
  2. 2 Whether the mother engaged in alienating behaviours and false allegations against the father
  3. 3 Whether either parent's conduct has impacted the welfare of the subject child, E

Ratio Decidendi

The court found that while some of the mother's allegations of emotional and physical abuse by the father were established on the balance of probabilities, the most serious allegations of sexual abuse and rape were not proven. The court found the father engaged in emotionally abusive and inappropriate behaviour towards the children, including verbal belittling and physical chastisement, but did not find evidence of sexual abuse or grooming. The court found the mother had, at times, engaged in behaviour that undermined the father's relationship with the children but did not find a pattern of deliberate alienation. The findings inform future welfare decisions for E.

Court Disposition

Findings of fact made; mixed findings against both parents; no findings of sexual abuse or rape; findings of emotional and some physical abuse by the father; findings of some undermining behaviour by the mother but not deliberate alienation.

Orders

  • Findings to inform future welfare decisions for E.
  • No immediate change to child arrangements pending welfare hearing.