F v M & Anor [2025] EWFC 454 (B) (16 December 2025)

F v M & Anor [2025] EWFC 454 (B) (16 December 2025)

The court found that while M engaged in some inappropriate practices (such as worry notes and voice recordings) that risked reinforcing A’s anxieties and failed to adapt routines or facilitate some contact, these actions were not deliberate or malicious and did not amount to alienating behaviours. A’s reluctance to spend time with F was caused by a combination of chronic parental conflict, differing parenting styles, and mismanagement of anxieties, not solely by M’s psychological manipulation. The burden of proof for alienation was not met.

Citation
[2025] EWFC 454 (B)
Parties
Applicant: F; First Respondent: M; Second Respondent: A, through her Children's Guardian, Emma Brown
Jurisdiction
England and Wales
Judgment Date
16 December 2025
Procedural Posture
Children Act Proceedings (private Law) / Fact Finding Hearing
Outcome
Findings made on some factual allegations but not on alienating behaviours; no finding of parental alienation against M.
Legal Topics
Child Arrangements Order, Parental Alienation, Fact Finding Hearing, Practice Direction 12 J, Welfare of the Child
Family Law Child Arrangements Order Parental Alienation Fact Finding Hearing Practice Direction 12 J Welfare of the Child

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Parties

F

Applicant

M

First Respondent

A, through her Children's Guardian, Emma Brown

Second Respondent

Procedural Posture

Children Act Proceedings (private Law) / Fact Finding Hearing

Legal Issues

  1. 1 Whether M engaged in alienating behaviours towards A against F
  2. 2 Whether M's conduct amounted to psychological manipulation of A
  3. 3 Whether M's actions were controlling or failed to collaborate with F in parenting

Ratio Decidendi

The court found that while M engaged in some inappropriate practices (such as worry notes and voice recordings) that risked reinforcing A’s anxieties and failed to adapt routines or facilitate some contact, these actions were not deliberate or malicious and did not amount to alienating behaviours. A’s reluctance to spend time with F was caused by a combination of chronic parental conflict, differing parenting styles, and mismanagement of anxieties, not solely by M’s psychological manipulation. The burden of proof for alienation was not met.

Court Disposition

Findings made on some factual allegations but not on alienating behaviours; no finding of parental alienation against M.

Orders

  • A to spend time with F from end of school on 12 December 2025 until morning of 19 December 2025.
  • A to spend weekends of 17-18 January 2026 and 24-25 January 2026 with F.