D v E (Welfare Decision following Findings of Domestic Abuse) [2026] EWFC 77 (B) (24 March 2026)

D v E (Welfare Decision following Findings of Domestic Abuse) [2026] EWFC 77 (B) (24 March 2026)

Direct contact between C and her father D is not emotionally safe and is causing ongoing harm due to the father's coercive and controlling behaviour, lack of insight, and failure to undertake meaningful domestic abuse work. The presumption of parental involvement does not apply due to risk of harm. A section 91(14) order is justified to prevent further harmful or vexatious applications. The prohibited steps order regarding medical information is necessary to prevent further coercive behaviour. Publication of anonymised judgments is permitted.

Citation
[2026] EWFC 77 (B)
Parties
Child: CDE; Mother: E; Father: D
Jurisdiction
England and Wales
Judgment Date
24 March 2026
Procedural Posture
Children Act 1989 Welfare Proceedings / Final Welfare Judgment Following Fact Finding
Outcome
Direct contact between C and her father is ceased; all contact orders discharged. No order for indirect contact. Prohibited steps order regarding medical information continued. Section 91(14) order made. Anonymised publication of both judgments permitted.
Legal Topics
Domestic Abuse, Child Contact, Prohibited Steps Order, Section 91(14) Orders, Welfare Checklist, Parental Involvement Presumption, Publication of Judgments
Family Law Child Law Domestic Abuse Child Contact Prohibited Steps Order Section 91(14) Orders Welfare Checklist Parental Involvement Presumption +1 more

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Parties

CDE

Child

E

Mother

D

Father

Procedural Posture

Children Act 1989 Welfare Proceedings / Final Welfare Judgment Following Fact Finding

Legal Issues

  1. 1 Whether direct or indirect contact between C and her father D should continue in light of findings of domestic abuse
  2. 2 Whether a prohibited steps order regarding medical information should be continued
  3. 3 Whether a section 91(14) Children Act 1989 order should be made to restrict further applications

Ratio Decidendi

Direct contact between C and her father D is not emotionally safe and is causing ongoing harm due to the father's coercive and controlling behaviour, lack of insight, and failure to undertake meaningful domestic abuse work. The presumption of parental involvement does not apply due to risk of harm. A section 91(14) order is justified to prevent further harmful or vexatious applications. The prohibited steps order regarding medical information is necessary to prevent further coercive behaviour. Publication of anonymised judgments is permitted.

Court Disposition

Direct contact between C and her father is ceased; all contact orders discharged. No order for indirect contact. Prohibited steps order regarding medical information continued. Section 91(14) order made. Anonymised publication of both judgments permitted.

Orders

  • Cessation of all direct contact between C and D; discharge of all contact orders
  • No order for indirect contact