MK v FJ & XY (Composite Hearing: Alienating Behaviours), Re

MK v FJ & XY (Composite Hearing: Alienating Behaviours), Re

On the balance of probabilities, the mother has engaged in alienating behaviours that have emotionally harmed the child and undermined her relationship with the father. The child’s resistance and negative views towards the father are not fully justified by alignment, affinity, or attachment, nor by the father's conduct. The child’s welfare requires a structured contact regime, continued residence with the mother, and a section 91(14) order for 2 years. A deferred or suspended change of residence is not in the child’s best interests.

Parties
Applicant: MK; First Respondent: FJ; Second Respondent: XY (through her Children’s Guardian)
Jurisdiction
England and Wales
Judgment Date
20 October 2025
Procedural Posture
Family / Final Composite Hearing With Fact Finding and Welfare Determination
Outcome
Findings of alienating behaviour against the mother; child to remain living with mother; structured contact with father; section 91(14) order for 2 years; suspended change of residence refused.
Legal Topics
Parental Alienation, Child Arrangements, Contact Orders, Section 91(14) Children Act 1989, Welfare Checklist, Fact Finding Hearings
Family Law Child Law Parental Alienation Child Arrangements Contact Orders Section 91(14) Children Act 1989 Welfare Checklist Fact Finding Hearings

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Parties

MK

Applicant

FJ

First Respondent

XY (through her Children’s Guardian)

Second Respondent

Procedural Posture

Family / Final Composite Hearing With Fact Finding and Welfare Determination

Legal Issues

  1. 1 Whether the mother engaged in alienating behaviours towards the father
  2. 2 Whether a deferred or suspended change of residence is appropriate
  3. 3 What contact arrangements are in the child's best interests

Ratio Decidendi

On the balance of probabilities, the mother has engaged in alienating behaviours that have emotionally harmed the child and undermined her relationship with the father. The child’s resistance and negative views towards the father are not fully justified by alignment, affinity, or attachment, nor by the father's conduct. The child’s welfare requires a structured contact regime, continued residence with the mother, and a section 91(14) order for 2 years. A deferred or suspended change of residence is not in the child’s best interests.

Court Disposition

Findings of alienating behaviour against the mother; child to remain living with mother; structured contact with father; section 91(14) order for 2 years; suspended change of residence refused.

Orders

  • Lives with order in favour of the mother
  • Structured contact: alternate Saturdays and Sundays with father, progressing to overnight and midweek contact as appropriate