F v M & Anor

F v M & Anor

The court found that A's reluctance to spend time with F was caused by chronic parental conflict, differing parenting styles, and mismanagement of A's anxieties by M, but not by deliberate alienating behaviours or psychological manipulation by M. The evidence did not establish alienation as defined by relevant case law and guidance.

Parties
Applicant: F; First Respondent: M; Second Respondent: A, through her Children’s Guardian, Emma Brown
Jurisdiction
England and Wales
Judgment Date
17 December 2025
Procedural Posture
Children Act Proceedings (private Law) / Fact Finding Hearing
Outcome
Allegations of alienating behaviour not proved; findings made on some subsidiary allegations; arrangements for A determined for Christmas and January.
Legal Topics
Child Arrangements Order, Parental Alienation, Fact Finding, Domestic Abuse, Case Management

Case Brief

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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

  1. 1 Whether M engaged in alienating behaviours against F
  2. 2 Whether M's actions constituted psychological manipulation of A
  3. 3 Whether M's conduct impacted A's relationship with F

Ratio Decidendi

The court found that A's reluctance to spend time with F was caused by chronic parental conflict, differing parenting styles, and mismanagement of A's anxieties by M, but not by deliberate alienating behaviours or psychological manipulation by M. The evidence did not establish alienation as defined by relevant case law and guidance.

Court Disposition

Allegations of alienating behaviour not proved; findings made on some subsidiary allegations; arrangements for A determined for Christmas and January.

Orders

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