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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.
The court found the mother had made false rape allegations against the father, perpetrated domestic abuse towards the children and father, exposed her daughter B to a serious safeguarding risk, harassed the family, and engaged in malicious communications. The children expressed clear wishes to remain with their father and not have direct contact with their mother. The court determined that the children's welfare required that they continue to live with their father, that only indirect contact with the mother be permitted, and that protective orders remain in place to ensure stability and prev…
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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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RA v PK (Rev1) [2025] EWHC 3456 (Fam) (15 December 2025)
The High Court refused the father contact, made a section 91(14) order until the child is 13, and restricted his parental responsibility because contact risked re-traumatising the child and mother.
F v M & Ors [2025] EWFC 433 (B) (24 November 2025)
The Family Court made X live with her father, refused the mother’s relocation request, ordered supervised contact only, and imposed a section 91(14) bar until age 13.
Appeal partly allowed against a section 91(14) order. The court held the blanket three-year restriction was disproportionate and tailored the restrictions by application type.
D v E (Findings of Domestic Abuse) [2025] EWFC 506 (B) (25 September 2025)
Direct contact between C and her father is to cease because it is not emotionally safe for C and is causing ongoing harm due to the father's coercive and controlling behaviour, lack of genuine insight or change, and the need for C and her mother to repair their relationship. A section 91(14) order is justified to prevent further applications without leave, given the history of abuse and litigation. The prohibited steps order regarding medical information is to continue. Anonymised publication of judgments is permitted.
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The court made a final care order for a 16-year-old girl to remain in residential care, citing relapse risk, parental obstruction, and the need for stable support.
X's welfare can only be safeguarded by a final lives with order in favour of the father and indefinite supervised contact for the mother due to high risk of abduction, emotional harm, neglect, and mother's unaddressed mental health and drug use. Section 91(14) order is necessary to prevent further litigation causing harm to X. Mother's relocation application is dismissed due to lack of evidence and risk factors.
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