F v M

F v M

The Deputy District Judge erred by excluding the allegation of non-consensual sexual touching from the fact-finding hearing, as it should have been considered as part of an alleged pattern of controlling and coercive behaviour relevant to the assessment of risk to the child. The exclusion was wrong in law and contrary to established principles for handling domestic abuse allegations in family proceedings.

Parties
Appellant: M; Respondent: F
Jurisdiction
England and Wales
Judgment Date
17 February 2022
Procedural Posture
Family Appeal / Appeal Judgment
Outcome
Appeal allowed
Legal Topics
Domestic Abuse, Fact Finding Hearings, Case Management, Child Arrangements, Controlling and Coercive Behaviour

Case Brief

Summary, issues, holding and outcome

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Parties

M

Appellant

F

Respondent

Procedural Posture

Family Appeal / Appeal Judgment

  1. 1 Whether the Deputy District Judge erred in excluding the allegation of non-consensual sexual touching from the fact-finding hearing
  2. 2 Whether the exclusion affected the assessment of risk to the child

Ratio Decidendi

The Deputy District Judge erred by excluding the allegation of non-consensual sexual touching from the fact-finding hearing, as it should have been considered as part of an alleged pattern of controlling and coercive behaviour relevant to the assessment of risk to the child. The exclusion was wrong in law and contrary to established principles for handling domestic abuse allegations in family proceedings.

Court Disposition

Appeal allowed

Orders

  • The allegation of non-consensual sexual touching to be determined at the fact-finding hearing.
  • Narrative statements to be provided by each parent as directed.