A v R (Appeal: Unsupervised Contact Prior to Determination of Allegations: PD12J)

A v R (Appeal: Unsupervised Contact Prior to Determination of Allegations: PD12J)

The District Judge erred by progressing contact to unsupervised prior to determination of serious domestic abuse allegations, failing to properly apply Practice Direction 12J paragraphs 25-27 and the welfare checklist, thereby exposing the child and mother to unmanageable risk of harm.

Parties
Applicant: A; Respondent: R
Jurisdiction
England and Wales
Judgment Date
19 March 2026
Procedural Posture
Family Law Appeal / Judgment on Appeal Against Interim Contact Order
Outcome
Appeal allowed; permission to appeal out of time granted.
Legal Topics
Interim Child Arrangements, Domestic Abuse Allegations, Practice Direction 12 J, Fact Finding Hearings, Supervised Vs Unsupervised Contact
Family Law Child Welfare Interim Child Arrangements Domestic Abuse Allegations Practice Direction 12 J Fact Finding Hearings Supervised Vs Unsupervised Contact

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Parties

A

Applicant

R

Respondent

Procedural Posture

Family Law Appeal / Judgment on Appeal Against Interim Contact Order

Legal Issues

  1. 1 Whether the District Judge erred in progressing contact to unsupervised prior to determination of domestic abuse allegations
  2. 2 Proper application of Practice Direction 12J paragraphs 25-27 in interim contact decisions

Ratio Decidendi

The District Judge erred by progressing contact to unsupervised prior to determination of serious domestic abuse allegations, failing to properly apply Practice Direction 12J paragraphs 25-27 and the welfare checklist, thereby exposing the child and mother to unmanageable risk of harm.

Court Disposition

Appeal allowed; permission to appeal out of time granted.

Orders

  • Order for unsupervised contact set aside.
  • Contact between father and child to be professionally supervised as per 11 November 2024 order.