G (Children) (Supervised Contact), Re

G (Children) (Supervised Contact), Re

The judge was entitled to accept the expert evidence that the father had narcissistic personality traits creating a risk of future harm, and to structure a phased contact order dependent on engagement with therapy, balancing the children’s welfare and gradual progression of contact. The judge’s evaluation of risk,...

Source-derived case information.

Parties
Appellant: LKM; Respondent: NPM
Jurisdiction
England and Wales
Judgment Date
11 October 2024
Procedural Posture
Family Appeal / Appeal Judgment
Outcome
appeal dismissed
Legal Topics
Child Contact, Supervised Contact, Risk Assessment, Psychotherapy, Welfare of Children, Parental Responsibility, Emotional Abuse, Physical Abuse, Expert Evidence
Family Law Child Contact Supervised Contact Risk Assessment Psychotherapy Welfare of Children Parental Responsibility Emotional Abuse +2 more

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Summary, issues, holding and outcome

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Parties

LKM

Appellant

NPM

Respondent

Procedural Posture

Family Appeal / Appeal Judgment

Legal Issues

  1. 1 Whether the judge failed to adequately identify the type and likelihood of risk posed by the father
  2. 2 Whether the judge placed disproportionate weight on the evidence of Dr Judith Freedman
  3. 3 Whether the requirement for continued therapy imposed a disproportionate restriction on the father’s contact

Ratio Decidendi

The judge was entitled to accept the expert evidence that the father had narcissistic personality traits creating a risk of future harm, and to structure a phased contact order dependent on engagement with therapy, balancing the children’s welfare and gradual progression of contact. The judge’s evaluation of risk, evidence, and proportionality was not erroneous or disproportionate.

Court Disposition

appeal dismissed

Orders

  • Phased progression from supervised to unsupervised contact as ordered by the judge
  • Father to engage in psychotherapy with a qualified psychiatrist/psychotherapist