England and Wales Case Law

A v R (Appeal: Unsupervised Contact Prior to Determination of Allegations: PD12J)

The District Judge erred by progressing contact to unsupervised prior to determination of serious domestic abuse allegations, failing to properly apply Practice Direction 12J paragraphs 25-27 and the welfare checklist, thereby exposing the child and mother to unmanageable risk of harm.

Source excerpt

• Interim child arrangements
• Domestic abuse allegations
• Practice direction 12j
• Fact-finding hearings
• Supervised vs unsupervised contact

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F v M & Anor

F v M & Anor [2025] EWFC 454 (B) (16 December 2025)

Fact-finding in Children Act proceedings. Some parental misconduct was found, but the court held the evidence did not establish alienating behaviour by M.

• Child arrangements order
• Parental alienation
• Fact-finding hearing
• Practice direction 12j
• Welfare of the child
• Child-arrangements-order

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L v D

L v D [2025] EWFC 516 (B) (04 December 2025)

After a three-day fact-finding hearing, the court made mixed findings of domestic abuse between the parents and ordered the findings recorded for welfare decisions.

• Domestic abuse
• Child arrangements order
• Parental responsibility
• Specific issue order
• Prohibited steps order
• Fact-finding hearing

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S & T (Children: Domestic Abuse)

S & T (Children: Domestic Abuse) [2025] EWFC 312 (B) (28 July 2025)

Private law children proceedings concerning domestic abuse findings, supervised contact, cross non-molestation applications, and a s.91(14) restriction.

• Child arrangements order
• Non-molestation order
• Section 91(14) children act 1989
• Practice direction 12j
• Coercive and controlling behaviour
• Supervised contact

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A v R (Appeal: Unsupervised Contact Prior to Determination of Allegations: PD12J)

A v R (Appeal: Unsupervised Contact Prior to Determination of Allegations: PD12J) [2025] EWFC 503 (B) (22 July 2025)

The Family Court allowed a mother’s out-of-time appeal, restoring professionally supervised contact while domestic abuse allegations await fact-finding.

• Child arrangements
• Domestic abuse
• Practice direction 12j
• Fact-finding hearings
• Interim orders
• Child-arrangements

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J (a Child) (No. 2) (Change of Residence), Re

J (a Child) (No. 2) (Change of Residence), Re [2025] EWFC 490 (B) (16 July 2025)

Given the mother's abusive conduct, breaches of court orders, lack of insight or remorse, and the risk of harm to both the father and J, the court finds that only indirect contact is safe and proportionate at this time. The mother must undertake meaningful work to address her behaviour before direct contact can be reconsidered. The Non-Molestation Order is extended for three years, and a Section 91(14) order is made for three years to protect J from further litigation. Disclosure of the mother's witness statements to the police is permitted.

Source excerpt

• Child arrangements
• Contact orders
• Non-molestation orders
• Section 91(14) orders
• Domestic abuse
• Prohibited steps orders

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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

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

The court found, on a balance of probabilities, that the father engaged in a sustained pattern of physical, emotional, psychological, financial, and litigation abuse against the mother and children, amounting to coercive and controlling behaviour. The evidence established that the father's conduct justified extension of the non-molestation order and required safeguarding measures for child contact.

Source excerpt

• Coercive and controlling behaviour
• Non-molestation orders
• Child arrangements
• Financial abuse
• Credibility assessment
• Practice direction 12j

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A Mother v A Father

A Mother v A Father [2025] EWFC 345 (B) (29 January 2025)

Fact-finding judgment in child proceedings where the court found the father had committed domestic abuse and coercive control against the mother.

• Domestic abuse
• Child arrangements
• Fact-finding
• Coercive and controlling behaviour
• Practice direction 12j
• Domestic-abuse

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A Father v A Mother

A Father v A Mother [2024] EWHC 3125 (Fam) (22 November 2024)

The High Court refused a father’s application for the summary return of an 8-month-old child to a non-Hague country, finding return was not in the child’s best interests.

• Inherent jurisdiction
• Summary return
• Child welfare
• Domestic abuse allegations
• Jurisdictional issues
• Practice direction 12j

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