England and Wales Case Law

JX (A Child) (Fact-finding hearing), Re

Both parties perpetrated domestic abuse in a toxic, volatile relationship. The mother was physically abusive towards the father, including hitting, threats, and loss of self-control, some of which she admitted. The father engaged in emotionally controlling and dismissive behaviour, including stonewalling, unilateral decision-making post-separation, and conduct likely to cause the mother emotional harm and ongoing control using the child. Both parties' behaviours caused emotional harm to the child. The court found specific allegations proven or part-proven as detailed, and determined that both…

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• Domestic abuse
• Coercive and controlling behaviour
• Physical abuse
• Child arrangements
• Parental responsibility
• Contact arrangements

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Angela v Robert

The respondent's conduct, including emotional manipulation, threats, unreasonable demands, and persistent behaviour, amounted to emotional abuse, coercive and controlling behaviour under the Domestic Abuse Act 2021, justifying the continuation of the non-molestation order and influencing child arrangements.

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• Non-molestation order
• Child arrangements
• Prohibited steps order
• Specific issue order
• Coercive and controlling behaviour
• Emotional abuse

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A Father v A Mother

In a Children Act fact-finding hearing, the court made findings on domestic abuse allegations, child exposure to cannabis, and a car fire, but rejected coercive control.

• Domestic abuse
• Child arrangements
• Fact-finding
• Coercive and controlling behaviour
• Drug use
• Verbal abuse

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A Father v A Mother

A Father v A Mother [2026] EWFC 98 (B) (29 April 2026)

Fact-finding judgment in Children Act proceedings. The court largely upheld the mother’s domestic abuse allegations, rejected the father’s counter-allegations, and found no coercive control.

• Domestic abuse
• Child arrangements
• Fact-finding hearings
• Coercive and controlling behaviour
• Verbal abuse
• Drug use

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Welsh, R. v

Welsh, R. v [2026] EWCA Crim 595 (17 April 2026)

The Court of Appeal upheld a 42-month sentence for coercive control, dangerous driving, and driving while disqualified, and clarified the disqualification order.

• Coercive and controlling behaviour
• Dangerous driving
• Driving whilst disqualified
• Sentencing guidelines
• Domestic abuse
• Coercive-and-controlling-behaviour

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C, Re (Fact Finding Hearing)

C, Re (Fact Finding Hearing) [2026] EWFC 74 (B) (31 March 2026)

In a Children Act fact-finding hearing, the court rejected overarching coercive control but found several incidents of physical abuse and alcohol-related misconduct by the father.

• Domestic abuse
• Coercive and controlling behaviour
• Child arrangements order
• Physical assault
• Alcohol misuse
• Welfare of the child

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Nottinghamshire County Council v JW & Anor

Nottinghamshire County Council v JW & Anor [2026] EWCOP 13 (T2) (19 March 2026)

The Court of Protection held that JW had capacity in all material areas. The judge rejected the local authority’s case that her borderline intellectual functioning defeated capacity.

• Mental capacity act 2005
• Capacity assessment
• Coercive and controlling behaviour
• Borderline intellectual functioning
• Best interests
• Expert evidence

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Nottinghamshire County Council v JW & Anor

The Court of Protection held that JW had capacity in all material areas. It rejected incapacity based on borderline intellectual functioning and SW’s influence.

• Capacity assessment
• Coercive and controlling behaviour
• Borderline intellectual functioning
• Diagnostic and functional tests
• Causative nexus
• Autonomy

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R v Chay Thornton

The original sentence was unduly lenient given the seriousness, persistence, and aggravating features of the offending; immediate custodial sentences were required for each count, with credit for the guilty plea reducing the term to 34 months' imprisonment per count, to run concurrently.

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• Sentencing
• Domestic violence
• Coercive and controlling behaviour
• Intentional strangulation
• Appeals
• Attorney general's reference

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H (International relocation; controlling or coercive behaviour; covert recordings; half-sibling tie), Re

The court found that the Father engaged in a pattern of coercive and controlling behaviour, including financial and emotional abuse, supported by covert recordings, police and safeguarding records, and the Mother’s credible evidence. This behaviour adversely affected the Mother’s mental health and parenting capacity, and posed a risk of emotional harm to H. The Mother’s relocation plan to South Africa, with robust contact arrangements and enforceability safeguards, best secures H’s welfare by providing stable, supported care and reducing exposure to conflict. The interference with the Father’…

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• Child arrangements
• Relocation
• Domestic abuse
• Welfare of the child
• Coercive and controlling behaviour

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