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England and Wales decisions
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The Family Court extended protective orders for a nearly 17-year-old child, maintained indirect contact only with the father, and imposed a section 91(14) restraint.
M v F & Anor [2026] EWFC 106 (B) (13 May 2026)
The Family Court extended protective orders for a nearly 17-year-old child, continued indirect-only contact with the father, and made a section 91(14) order.
AF v RM [2026] EWFC 105 (B) (09 March 2026)
The court found AF in contempt for breaching a child arrangements order by sending confidential documents and trying to contact the children via schoolchildren.
The court made a child arrangements order for three children to live with their mother in Sweden, removed the father’s parental responsibility, and granted a non-molestation order.
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 trauma caused by the father's past violent and threatening behaviour outweighs the general presumption of parental involvement; contact is not in the child's best interest, section 91(14) order is justified to prevent further harm, and restrictions on parental responsibility are warranted to protect the child and mother.
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The court found extensive domestic abuse by F against M and the children, determined that the children should live with M with only indirect contact with F pending completion of domestic abuse and anger management programmes, and concluded that international relocation could not be granted at this stage but permission to travel was appropriate, with relocation application adjourned for further consideration.
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XR v ZP [2025] EWFC 408 (B) (18 November 2025)
The court discharged supervised contact and instead allowed only screened indirect contact, finding direct contact too risky given inconsistency and ongoing criminal proceedings.
M v F (Domestic Abuse: International Relocation) [2025] EWFC 360 (15 October 2025)
The court made further findings of serious domestic abuse, ordered the children to live with their mother, kept indirect contact with the father, and imposed intervention requirements before direct contact.
Leave to apply for post-adoption direct contact is refused because there is an almost guaranteed risk of emotional harm and disruption to X’s welfare if direct contact were to occur now. The evidence, particularly from the CAMHS specialist, established that X is emotionally vulnerable and not ready for direct contact. The child’s welfare, stability, and ongoing therapeutic work take precedence. Indirect contact and life story work are sufficient at this stage.
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