C (A Child), Re (Section 91(14) Children Act 1989 order) [2025] EWFC 363 (B) (07 October 2025)

C (A Child), Re (Section 91(14) Children Act 1989 order) [2025] EWFC 363 (B) (07 October 2025)

The April 2025 order should remain in place, save for deletion of the provision for overnight contact during October 2025 half-term, as immediate overnight contact is not in C's best interests. A 12-month section 91(14) order is necessary to protect C from emotional harm caused by continued litigation, restraining both parents from making further applications regarding C's living or contact arrangements without leave until 7 October 2026.

Citation
[2025] EWFC 363 (B)
Parties
Applicant: F; Respondent: M
Jurisdiction
England and Wales
Judgment Date
07 October 2025
Procedural Posture
Children Act 1989 Proceedings (section 8, Section 91(14)) / Final Hearing on Application to Vary Order and for Section 91(14) Order
Outcome
Application to vary order refused save for deletion of overnight contact in October 2025 half-term; section 91(14) order made against both parents for 12 months.
Legal Topics
Section 8 Orders, Section 91(14) Orders, Child Arrangements, Welfare of the Child, Litigation Restraint Orders
Family Law Child Law Section 8 Orders Section 91(14) Orders Child Arrangements Welfare of the Child Litigation Restraint Orders

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 6 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

F

Applicant

M

Respondent

Procedural Posture

Children Act 1989 Proceedings (section 8, Section 91(14)) / Final Hearing on Application to Vary Order and for Section 91(14) Order

Legal Issues

  1. 1 Whether to vary the April 2025 child arrangements order to allow overnight contact
  2. 2 Whether to make a section 91(14) order restraining further applications without leave

Ratio Decidendi

The April 2025 order should remain in place, save for deletion of the provision for overnight contact during October 2025 half-term, as immediate overnight contact is not in C's best interests. A 12-month section 91(14) order is necessary to protect C from emotional harm caused by continued litigation, restraining both parents from making further applications regarding C's living or contact arrangements without leave until 7 October 2026.

Court Disposition

Application to vary order refused save for deletion of overnight contact in October 2025 half-term; section 91(14) order made against both parents for 12 months.

Orders

  • April 2025 order to remain in force except for deletion of paragraph 17(h) (overnight contact in October 2025 half-term)
  • Staying contact to commence at Christmas 2025