M v F & Ors [2025] EWFC 442 (B) (05 November 2025)

M v F & Ors [2025] EWFC 442 (B) (05 November 2025)

The court cannot rely on expert evidence that fails to engage with or assess the impact of findings of controlling and coercive behaviour. The father's lack of insight and continued minimisation of abuse, combined with the risk of emotional harm to the children and the mother's vulnerability, mean that a shared care...

Source-derived case information.

Citation
[2025] EWFC 442 (B)
Parties
Applicant: M; 1st Respondent: F; 2nd – 3rd Respondents: X & Y (children by their Children's Guardian, NYAS Caseworker, Natalie Bell)
Jurisdiction
England and Wales
Judgment Date
05 November 2025
Procedural Posture
Private Law Children Proceedings / Final Judgment Following Fact Finding and Welfare Hearings
Outcome
Child arrangements order: children to live with the mother; defined supervised contact with the father; section 91(14) order made.
Legal Topics
Child Arrangements, Domestic Abuse, Welfare Principle, Parental Responsibility, Expert Evidence, Section 91(14) Orders
Family Law Child Arrangements Domestic Abuse Welfare Principle Parental Responsibility Expert Evidence Section 91(14) Orders

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Parties

M

Applicant

F

1st Respondent

X & Y (children by their Children's Guardian, NYAS Caseworker, Natalie Bell)

2nd – 3rd Respondents

Procedural Posture

Private Law Children Proceedings / Final Judgment Following Fact Finding and Welfare Hearings

Legal Issues

  1. 1 How should the court determine child arrangements where findings of controlling and coercive behaviour have been made against a parent?
  2. 2 What weight should be given to expert evidence that fails to engage with the court's findings of fact?
  3. 3 What is the significance of a parent's lack of insight into abusive behaviour for welfare decisions?

Ratio Decidendi

The court cannot rely on expert evidence that fails to engage with or assess the impact of findings of controlling and coercive behaviour. The father's lack of insight and continued minimisation of abuse, combined with the risk of emotional harm to the children and the mother's vulnerability, mean that a shared care arrangement is not in the children's best interests. The welfare of the children requires that they live with the mother and have defined, supervised contact with the father. A section 91(14) order is justified to prevent further harmful litigation.

Court Disposition

Child arrangements order: children to live with the mother; defined supervised contact with the father; section 91(14) order made.

Orders

  • Children to live with the mother.
  • Father to have supervised contact as specified in the order.