England and Wales Case Law

CF v CM (Finding of Fact Judgment 2)

The mother made and concealed a recording of X discussing the allegations, lied to her solicitors and the court about its existence, and took deliberate steps to destroy or withhold evidence. As a result, the process by which X was spoken to cannot be trusted, and the delay before the ABE interview, combined with the mother's lack of neutrality, means it cannot be proven on the balance of probabilities that the allegation of sexual abuse is true.

Source excerpt

• Fact-finding hearing
• Sexual abuse allegations
• Evidence concealment
• Rehearing procedure
• Witness credibility

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Girl (allegations of sexual abuse), Re

The Family Court found that allegations of sexual abuse, failure to protect, forced marriage and honour-based harm were not proved, so threshold was not crossed.

• Sexual abuse allegations
• Failure to protect
• Forced marriage
• Honour-based violence
• Police protection orders
• Threshold criteria under children act 1989

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A Local Authority v A Mother & Ors

A Local Authority v A Mother & Ors [2026] EWFC 102 (B) (09 April 2026)

Fact-finding judgment in care proceedings: the local authority failed to prove sexual abuse, failure to protect, or forced marriage and honour-based harm.

• Sexual abuse allegations
• Failure to protect
• Forced marriage
• Honour-based violence
• Threshold criteria under children act 1989
• Child-protection

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Manchester City Council v M & Ors

Fact-finding judgment in care proceedings finding that the father raped Ms Smith in 2015 and sexually abused child X on multiple occasions.

• Care proceedings
• Sexual abuse allegations
• Fact-finding hearings
• Threshold criteria
• Evidential standards
• Care-proceedings

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Manchester City Council v M & Ors

Manchester City Council v M & Ors [2026] EWFC 75 (01 April 2026)

Fact-finding in care proceedings: the court found the father raped Ms Smith in 2015, but did not make findings on all allegations concerning X.

• Care proceedings
• Sexual abuse allegations
• Fact-finding hearings
• Threshold criteria
• Dna evidence
• Child testimony

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Kent County Council v M & Ors

Kent County Council v M & Ors [2026] EWFC 60 (B) (02 March 2026)

The court found no proven historic sexual abuse by the father, but held both parents could not safely meet the child's needs. Care and placement orders were made.

• Care orders
• Placement orders
• Threshold criteria
• Sexual abuse allegations
• Neglect
• Parental capacity

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Medway Council v M & Ors

Medway Council v M & Ors [2026] EWFC 39 (B) (30 January 2026)

Fact-finding judgment in care proceedings concerning four children. The court found neglect, poor home conditions, excessive chores, and some physical harm.

• Care proceedings
• Threshold criteria
• Child neglect
• Sexual abuse allegations
• Fact finding
• Standard of proof

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A Father v A Mother (Sexual Abuse – procedural fairness)

The court found, on the balance of probabilities, that S displayed sexualised behaviour in 2022 caused by sexual abuse by her father, based primarily on the incident where S was found with her fingers in her knickers and said it was part of her secret with her daddy. Other incidents, while individually ambiguous, were interpreted in light of this finding. The court did not find that the father's verbal conduct met the statutory definition of domestic abuse.

Source excerpt

• Sexual abuse allegations
• Procedural fairness
• Domestic abuse
• Child arrangements

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A (A child) (Care Proceedings: Finding of Fact), Re

The court found the local authority proved sexual abuse findings against the father and concerns about the mother’s ability to protect Child A.

• Care orders
• Sexual abuse allegations
• Threshold criteria
• Parental responsibility
• Risk assessment
• Care-proceedings

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S (A Child), Re (Sexual Abuse - procedural fairness)

S (A Child), Re (Sexual Abuse - procedural fairness) [2025] EWFC 469 (B) (25 November 2025)

The court held that a father sexually abused his daughter, relying mainly on a child’s “secret with daddy” remark, but rejected a domestic abuse finding against the mother.

• Sexual abuse allegations
• Procedural fairness
• Domestic abuse
• Fact-finding hearings
• Child arrangements orders
• Child-sexual-abuse

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