England and Wales Case Law

X v Y & Anor

Permission is granted for disclosure of the judgment and order dated 28 February 2025 to the relevant Police conduct authority for both professional conduct review and respondent complaints, but not for wider disclosure of all case papers. Publication of this judgment is permitted, but only in anonymised form to protect the integrity of the police investigation and the parties' privacy.

Source excerpt

• Disclosure of judgments
• Professional standards for police officers
• Anonymisation of judgments
• Non molestation orders
• Open justice

Read case analysis

X (A Child) (Disclosure to the NMC), Re

The balance of interests favours permitting disclosure of the redacted judgment and Schedule of Findings to the NMC for the sole purpose of their Fitness to Practice investigation, as the public interest in safeguarding vulnerable adults outweighs the privacy rights of the child and father.

Source excerpt

• Disclosure of judgments
• Fitness to practice
• Safeguarding
• Privacy and confidentiality
• Inter-agency cooperation

Read case analysis

X v Y (Rev1)

X v Y (Rev1) [2025] EWFC 237 (B) (31 July 2025)

The Family Court allowed disclosure of an earlier judgment to police conduct bodies, refused wider disclosure of all papers, and permitted publication only in anonymised form.

• Disclosure of judgments
• Confidentiality in family proceedings
• Professional standards for police officers
• Anonymisation of judgments
• Publication of family court judgments
• Family-court-disclosure

Read case analysis

The BBC v A London Local Authority & Ors (Press Disclosure Application)

Disclosure of the judgments to the BBC is granted because the public interest in transparency and informed debate outweighs the risk of prejudicing the criminal trial, provided confidentiality of the children's identities is maintained through redaction and compliance with reporting restrictions.

Source excerpt

• Disclosure of judgments
• Reporting restrictions
• Anonymity
• Public interest
• Article 8 and article 10 balancing
• Transparency in family courts

Read case analysis

MZA v FHB (No 4) (private law - supplementary welfare judgment)

MZA v FHB (No 4) (private law - supplementary welfare judgment) [2025] EWFC 277 (B) (02 July 2025)

Supplementary welfare judgment in private children proceedings. The court ordered monthly supervised contact, refused a further risk assessment and guardian, and made a section 91(14) order.

• Child arrangements order
• Domestic abuse
• Section 91(14) orders
• Supervised contact
• Welfare checklist
• Practice direction 12j

Read case analysis

MZA v FHB (No 4) (private law - supplementary welfare judgment)

Given findings of serious and ongoing domestic abuse, lack of insight and change by the father, and the children's expressed feelings of unsafety, the court orders that contact be reduced and supervised, imposes a section 91(14) order to protect against further harmful litigation, refuses further expert assessment and guardian appointment, allows disclosure and publication of anonymised judgments, all to safeguard the welfare of the children and their mother.

Source excerpt

• Child arrangements
• Supervised contact
• Section 91(14) orders
• Disclosure of judgments
• Publication of judgments
• Coercive control

Read case analysis

MZA v FHB (No 2) (private law - fact-find)

MZA v FHB (No 2) (private law - fact-find) [2024] EWFC 467 (B) (30 July 2024)

Given findings of serious and ongoing domestic abuse, lack of insight or change by the father, and the children's clearly expressed feelings of unsafety, the presumption of parental involvement is rebutted. Supervised contact at reduced frequency is necessary to protect the children and mother from risk of harm. Further expert assessment or guardian appointment is unnecessary and would cause delay. A section 91(14) order is justified to prevent litigation being used as a tool of abuse and to protect the welfare of the children.

Source excerpt

• Child arrangements order
• Domestic abuse
• Section 91(14) orders
• Supervised contact
• Welfare checklist
• Practice direction 12j

Read case analysis

M v S

M v S [2024] EWFC 80 (B) (11 March 2024)

The Family Court refused disclosure of a fact-finding judgment to the father’s employer, declined interim supervised contact, and set directions on further evidence and a declaration application.

• Child contact
• Disclosure of judgments
• Domestic abuse findings
• Mental health evidence
• Declaration of incompatibility
• Safeguarding procedures

Read case analysis

The BBC v A London Local Authority & Ors (Press Disclosure Application)

The BBC v A London Local Authority & Ors (Press Disclosure Application) [2023] EWFC 310 (05 December 2023)

The BBC was granted disclosure of redacted family court judgments to prepare a future publication request after a criminal trial, with identity protection for the children.

• Disclosure of judgments
• Press access to family proceedings
• Anonymity and reporting restrictions
• Article 8 and article 10 echr balancing
• Transparency in the family court
• Family-law

Read case analysis

BR & Ors (Three Families: Fabricated or Induced Illness: Anonymisation, Disclosure of Judgment, and Permission to Appeal by Witness)

BR & Ors (Three Families: Fabricated or Induced Illness: Anonymisation, Disclosure of Judgment, and Permission to Appeal by Witness) [2023] EWFC 329 (06 July 2023)

The court kept a clinician anonymised, set a disclosure mechanism for other FII cases, refused appeal of an urgent disclosure order, and extended time to appeal findings.

• Anonymisation of judgments
• Disclosure of judgments
• Procedural fairness for witnesses
• Fabricated or induced illness (fii)
• Article 8 echr
• Article 10 echr

Read case analysis