S (Parental Alienation: Cult), Re

S (Parental Alienation: Cult), Re

The court found that the mother's adherence to Universal Medicine was causing actual and ongoing harm to Lara, including alienation from her father, and that the undertakings offered by the mother were insufficient to mitigate these risks. The judge below erred by not taking decisive action to address the harm and...

Source-derived case information.

Parties
Appellant: Father; Respondent: Mother
Jurisdiction
England and Wales
Judgment Date
29 April 2020
Procedural Posture
Child Arrangements Order Variation / Appeal Decision
Outcome
Appeal allowed; case remitted for final welfare determination.
Legal Topics
Parental Alienation, Freedom of Belief, Cult Influence, Child Arrangements, Prohibited Steps Order
Family Law Child Welfare Parental Alienation Freedom of Belief Cult Influence Child Arrangements Prohibited Steps Order

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Summary, issues, holding and outcome

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Parties

Father

Appellant

Mother

Respondent

Procedural Posture

Child Arrangements Order Variation / Appeal Decision

  1. 1 Whether the mother's adherence to Universal Medicine constitutes harm to the child
  2. 2 Whether parental alienation is occurring
  3. 3 Whether undertakings from the mother are sufficient to protect the child

Ratio Decidendi

The court found that the mother's adherence to Universal Medicine was causing actual and ongoing harm to Lara, including alienation from her father, and that the undertakings offered by the mother were insufficient to mitigate these risks. The judge below erred by not taking decisive action to address the harm and alienation, and by failing to ensure meaningful undertakings. The appeal was allowed, and the case remitted for a final welfare decision, with a warning that unless the mother makes a definitive break from Universal Medicine, Lara's care is likely to be transferred to the father.

Court Disposition

Appeal allowed; case remitted for final welfare determination.

Orders

  • Mother’s application for permission to cross-appeal refused.
  • Father’s appeal allowed.