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England and Wales decisions
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The court found the mother's allegations of sexual coercion, conditional consent rape, physical abuse, and controlling/coercive behaviour to be false, preferring the father's evidence and finding no behaviour by the father justifying continuation of any restrictive orders.
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L v P [2026] EWHC 1209 (Fam) (07 May 2026)
The High Court refused to set aside a 3-year Civil Restraint Order against a father after repeated meritless applications in child-contact litigation.
The father's failure to address or provide evidence regarding his domestic abuse and substance misuse, his lack of insight, and his non-compliance with court orders present ongoing risks to the child. The welfare of the child requires that no direct or indirect contact (other than limited provision of photographs) be ordered, and that a section 91(14) order be made to restrict further applications for five years.
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Given the identified risks—CF's unresolved pornography addiction and impulsivity, the risk of X developing false beliefs about past abuse, delay in re-establishing the father-child relationship, and CM's entrenched beliefs—the court determined that direct contact should not be ordered until all parties have completed recommended therapeutic interventions and their success is evidenced. Indirect contact is to continue, and a specific issue order is made for X to engage in therapy. The proceedings are concluded to avoid further delay, with the possibility of review after therapy completion.
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The court found, on the balance of probabilities, that H engaged in a pattern of domestic abuse against O, including physical violence, sexual assault (rape), controlling and humiliating behaviour, and threats. The court preferred O's evidence as more credible and consistent, corroborated by contemporaneous records and third-party statements. The court did not find the allegations of violence against the children proved but found the father's conduct towards O established a grave risk of harm and justified the findings sought.
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D v E (Welfare Decision following Findings of Domestic Abuse) [2026] EWFC 77 (B) (24 March 2026)
Following findings of domestic abuse, the court stopped all direct contact between a child and her father, continued a medical-information PSO, made a s91(14) order, and allowed anonymised publication.
A Child Born 2017, Re (Final Hearing) [2026] EWFC 55 (B) (27 February 2026)
The court refused direct child contact, allowed only photo-sharing, and made a five-year section 91(14) order after finding ongoing risks from domestic abuse and substance misuse.
The court found, on the balance of probabilities, that the father did not sexually assault or coerce the mother, nor act in a controlling manner. The mother was not a victim of coercive control. The court found that A was not sexually abused by a third-party while in the father's care, and the father was innocent of all related allegations. The court found that the mother emotionally manipulated the children, asked A leading questions to obtain evidence of sexual abuse, encouraged and influenced A to make false allegations, and suspended contact based on false allegations. The mother admitted…
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The Family Court made an extended civil restraint order against the father after multiple applications were declared totally without merit in ongoing private-law children proceedings.
Contact between FM and the children would cause significant emotional, psychological, and physical harm to the mother and children, with no mechanism to reduce those risks due to FM's lack of insight and ongoing abusive behaviour. Revocation of FM's parental responsibility, a section 91(14) order, and a non-molestation order are necessary and proportionate to safeguard the welfare of the children and the mother.
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