MK v FJ & XY (Composite Hearing: Alienating Behaviours) (Rev1) [2025] EWFC 326 (B) (05 June 2025)

MK v FJ & XY (Composite Hearing: Alienating Behaviours) (Rev1) [2025] EWFC 326 (B) (05 June 2025)

The court found that while the mother has exhibited some behaviours that could be considered alienating or influential, particularly through her language, body language, and focus on the father's cognitive limitations, the evidence does not support a finding of sustained or deliberate parental alienation. The...

Source-derived case information.

Citation
[2025] EWFC 326 (B)
Parties
Applicant: MK; First Respondent: FJ; Second Respondent: XY (through her Children's Guardian)
Jurisdiction
England and Wales
Judgment Date
05 June 2025
Procedural Posture
Private Law Children Proceedings / Final Composite Hearing With Fact Finding and Welfare Determination
Outcome
Application for findings of parental alienation dismissed; child to remain living with mother; structured contact with father ordered; section 91(14) order made for 12 months.
Legal Topics
Parental Alienation, Child Arrangements, Section 91(14) Children Act 1989, Welfare Checklist, Fact Finding Hearings, Contact Arrangements
Family Law Child Law Parental Alienation Child Arrangements Section 91(14) Children Act 1989 Welfare Checklist Fact Finding Hearings Contact Arrangements

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Parties

MK

Applicant

FJ

First Respondent

XY (through her Children's Guardian)

Second Respondent

Procedural Posture

Private Law Children Proceedings / Final Composite Hearing With Fact Finding and Welfare Determination

Legal Issues

  1. 1 Whether the mother engaged in alienating behaviours against the father
  2. 2 Appropriate child arrangements for XY
  3. 3 Whether a section 91(14) order should be made and for what duration

Ratio Decidendi

The court found that while the mother has exhibited some behaviours that could be considered alienating or influential, particularly through her language, body language, and focus on the father's cognitive limitations, the evidence does not support a finding of sustained or deliberate parental alienation. The child's reluctance and resistance to contact with the father are influenced by a combination of factors, including alignment and attachment to the mother, exposure to adult conversations, and the ongoing conflict between parents. The court determined that the welfare of XY is best served by remaining with her mother, with a structured pattern of contact with the father, and a section...

Court Disposition

Application for findings of parental alienation dismissed; child to remain living with mother; structured contact with father ordered; section 91(14) order made for 12 months.

Orders

  • XY to live with her mother (MK)
  • Contact between XY and father (FJ) to follow Guardian's recommended pattern