F v M & Ors [2025] EWFC 433 (B) (24 November 2025)

F v M & Ors [2025] EWFC 433 (B) (24 November 2025)

The court found that X's welfare required her to live with her father, with only supervised contact with her mother due to the mother's emotional instability, untreated mental health issues, unregulated cannabis use, high flight risk, and persistent denigration of the father. The mother's application to relocate with X to Australia was refused as contrary to X's best interests. A section 91(14) order was made to restrict the mother from making further applications without permission until X is 13, to provide stability and respite. The father's application for costs was refused. The court discharged the Interim Care Order and made final child arrangements and prohibited steps orders as...

Citation
[2025] EWFC 433 (B)
Parties
Applicant: F; 1st Respondent: M; 2nd Respondent: X (a child, through their children's guardian); 3rd Respondent: Surrey County Council
Jurisdiction
England and Wales
Judgment Date
24 November 2025
Procedural Posture
Children Act 1989 Proceedings (private and Public Law) / Final Hearing and Judgment
Outcome
Mother's application to relocate refused; child to live with father; supervised contact only with mother; section 91(14) order made; costs application refused.
Legal Topics
Child Arrangements Order, Relocation (international), Interim Care Order, Section 91(14) Order, Prohibited Steps Order, Parental Responsibility, Supervised Contact, Costs
Family Law Child Law Child Arrangements Order Relocation (international) Interim Care Order Section 91(14) Order Prohibited Steps Order Parental Responsibility +2 more

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Parties

F

Applicant

M

1st Respondent

X (a child, through their children's guardian)

2nd Respondent

Surrey County Council

3rd Respondent

Procedural Posture

Children Act 1989 Proceedings (private and Public Law) / Final Hearing and Judgment

Legal Issues

  1. 1 With whom the child X should live and the nature of contact with the non-resident parent
  2. 2 Whether the mother should be permitted to relocate to Australia with X
  3. 3 Whether a section 91(14) order should be made to restrict further applications by the mother

Ratio Decidendi

The court found that X's welfare required her to live with her father, with only supervised contact with her mother due to the mother's emotional instability, untreated mental health issues, unregulated cannabis use, high flight risk, and persistent denigration of the father. The mother's application to relocate with X to Australia was refused as contrary to X's best interests. A section 91(14) order was made to restrict the mother from making further applications without permission until X is 13, to provide stability and respite. The father's application for costs was refused. The court discharged the Interim Care Order and made final child arrangements and prohibited steps orders as...

Court Disposition

Mother's application to relocate refused; child to live with father; supervised contact only with mother; section 91(14) order made; costs application refused.

Orders

  • Discharge of Interim Care Order
  • Child Arrangements Order: X to live with father