J (a Child) (No. 2) (Contact Following Change of Residence), Re

J (a Child) (No. 2) (Contact Following Change of Residence), Re

The mother’s conduct has been abusive, unpredictable, and in breach of undertakings and orders, posing a high risk of further harm to the father and emotional harm to J. The mandatory provisions of Practice Direction 12J cannot be met by supervised contact, as the father’s safety cannot be secured. Indirect contact...

Source-derived case information.

Parties
Applicant: A Father; Respondent: A Mother
Jurisdiction
England and Wales
Judgment Date
02 October 2026
Procedural Posture
Children Act 1989 Proceedings / Final Hearing
Outcome
Indirect contact only between J and the mother; Section 91(14) order for three years; Non-Molestation Order extended for three years; permission to disclose mother’s witness statements to police; Prohibited Steps Order remains in place.
Legal Topics
Child Arrangements, Contact Orders, Domestic Abuse, Non Molestation Orders, Section 91(14) Orders, Prohibited Steps Orders, Article 8 ECHR
Family Law Child Arrangements Contact Orders Domestic Abuse Non Molestation Orders Section 91(14) Orders Prohibited Steps Orders Article 8 ECHR

Source-derived case record

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Parties

A Father

Applicant

A Mother

Respondent

Procedural Posture

Children Act 1989 Proceedings / Final Hearing

Legal Issues

  1. 1 Whether direct contact between J and the mother should be reinstated or restricted to indirect contact only
  2. 2 Whether the Non-Molestation Order should be extended
  3. 3 Whether a Section 91(14) order should be made to restrict further applications

Ratio Decidendi

The mother’s conduct has been abusive, unpredictable, and in breach of undertakings and orders, posing a high risk of further harm to the father and emotional harm to J. The mandatory provisions of Practice Direction 12J cannot be met by supervised contact, as the father’s safety cannot be secured. Indirect contact only is ordered until the mother undertakes work to address her behaviour. Section 91(14) order is granted for three years to protect J from further litigation. Non-Molestation Order is extended for three years. Disclosure of the mother’s witness statements to the police is permitted.

Court Disposition

Indirect contact only between J and the mother; Section 91(14) order for three years; Non-Molestation Order extended for three years; permission to disclose mother’s witness statements to police; Prohibited Steps Order remains in place.

Orders

  • Discharge paragraphs 3 and 4 of order dated 16 July 2025
  • Indirect contact only between J and the mother at least monthly