M v F [2025] EWFC 257 (B) (11 August 2025)

M v F [2025] EWFC 257 (B) (11 August 2025)

Given the findings of severe and prolonged domestic abuse by F against M, F's complete lack of insight or acceptance of his behaviour, and the ongoing high risk of harm to both M and A, direct contact between A and F is not in A's welfare interests. Only indirect contact is appropriate, with safeguards to protect M and A. F's parental responsibility is to be restricted to prevent further coercive control. A section 91(14) order is necessary and proportionate to protect M and A from further litigation abuse and to provide respite, lasting until A transitions to secondary school.

Citation
[2025] EWFC 257 (B)
Parties
Applicant: F; First Respondent: M
Jurisdiction
England and Wales
Judgment Date
11 August 2025
Procedural Posture
Children Act 1989 Child Arrangements and Specific Issue Orders / Final Hearing Following Fact Finding and Dispute Resolution Hearings
Outcome
Child Arrangements Order for A to live with M; cessation of direct contact between A and F; indirect contact permitted with safeguards; restriction of F's parental responsibility; section 91(14) order made until 30 September 2030.
Legal Topics
Child Arrangements Order, Parental Responsibility, Domestic Abuse, Section 91(14) Orders, Contact Arrangements, Welfare Checklist
Family Law Child Law Child Arrangements Order Parental Responsibility Domestic Abuse Section 91(14) Orders Contact Arrangements Welfare Checklist

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Parties

F

Applicant

M

First Respondent

Procedural Posture

Children Act 1989 Child Arrangements and Specific Issue Orders / Final Hearing Following Fact Finding and Dispute Resolution Hearings

Legal Issues

  1. 1 Whether direct contact between A and F should continue
  2. 2 Whether to restrict F's parental responsibility
  3. 3 Whether to make a section 91(14) order and its duration

Ratio Decidendi

Given the findings of severe and prolonged domestic abuse by F against M, F's complete lack of insight or acceptance of his behaviour, and the ongoing high risk of harm to both M and A, direct contact between A and F is not in A's welfare interests. Only indirect contact is appropriate, with safeguards to protect M and A. F's parental responsibility is to be restricted to prevent further coercive control. A section 91(14) order is necessary and proportionate to protect M and A from further litigation abuse and to provide respite, lasting until A transitions to secondary school.

Court Disposition

Child Arrangements Order for A to live with M; cessation of direct contact between A and F; indirect contact permitted with safeguards; restriction of F's parental responsibility; section 91(14) order made until 30 September 2030.

Orders

  • A to live with M under a Child Arrangements Order.
  • Direct contact between A and F to cease.