E (A Child), Re (Disclosure to Regulator & Naming of a Witness in a Judgment) [2025] EWFC 423 (16 July 2025)

E (A Child), Re (Disclosure to Regulator & Naming of a Witness in a Judgment) [2025] EWFC 423 (16 July 2025)

The court held that the fact-finding judgment should be published and that Ms Dover, the psychotherapist, should be named in the published judgment. Anonymisation of professionals is only justified where necessary to protect the identity of the child or family, which can be achieved by redacting other identifying...

Source-derived case information.

Citation
[2025] EWFC 423
Parties
Applicant: Applicant (Father); First Respondent: First Respondent (Mother); Second Respondent: Second Respondent (Child, via Guardian); Interested Party (witness/psychotherapist): Aimee Dover
Jurisdiction
England and Wales
Judgment Date
16 July 2025
Procedural Posture
Private Law Children Act 1989 Proceedings (fact Finding and Associated Applications) / Post Fact Finding Hearing; Determination of Publication, Disclosure, and Anonymisation Issues
Outcome
Application granted in part; judgment to be published with Ms Dover named; disclosure to regulator and employers permitted; issue of naming parents adjourned.
Legal Topics
Anonymisation of Judgments, Disclosure to Regulators, Open Justice, Article 8 ECHR, Article 10 ECHR, Publication of Judgments, Professional Accountability, Transparency in Family Proceedings
Family Law Children Law Privacy Law Human Rights Anonymisation of Judgments Disclosure to Regulators Open Justice Article 8 ECHR +4 more

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Parties

Applicant (Father)

Applicant

First Respondent (Mother)

First Respondent

Second Respondent (Child, via Guardian)

Second Respondent

Aimee Dover

Interested Party (witness/psychotherapist)

Procedural Posture

Private Law Children Act 1989 Proceedings (fact Finding and Associated Applications) / Post Fact Finding Hearing; Determination of Publication, Disclosure, and Anonymisation Issues

Legal Issues

  1. 1 Should the fact-finding judgment be published and, if so, should the psychotherapist (Ms Dover) be named?
  2. 2 Should the judgment be disclosed to Ms Dover's regulatory body and current employers?
  3. 3 Does anonymisation of Ms Dover serve the Article 8 rights of the child or family?

Ratio Decidendi

The court held that the fact-finding judgment should be published and that Ms Dover, the psychotherapist, should be named in the published judgment. Anonymisation of professionals is only justified where necessary to protect the identity of the child or family, which can be achieved by redacting other identifying details. Speculative concerns about harassment or criticism are insufficient to outweigh the strong public interest in transparency and professional accountability. There is no evidence of a real risk of jigsaw identification or harm to the child if Ms Dover is named. Disclosure of the judgment to Ms Dover's regulatory body and current employers is permitted, as it serves the...

Court Disposition

Application granted in part; judgment to be published with Ms Dover named; disclosure to regulator and employers permitted; issue of naming parents adjourned.

Orders

  • The fact-finding judgment shall be published, with Ms Dover named as the psychotherapist involved.
  • Disclosure of the fact-finding judgment to Ms Dover's regulatory body, relevant LADO, and current employers is permitted.