Family Law Week judgment summary: Re G (supervised contact) [2023] EWCA 1453

12 December 2023

Dr Martina Van der Leij summarises a judgment for Family Law Week  about the dismissal of a father's appeal against progress in his contact with the children depending on his engagement with psychotherapy.

The fact finding determined that emotional abuse of the 2 children and mother arose from the father’s obsessive, anxious and rigid behaviour. Following this, a psychiatric expert was instructed to assess him. She considered that he had narcissistic personality traits which, if unaltered, could pose ongoing risks to the children if unsupervised contact took place. She recommended psychotherapy 2-3 times a week for 2 years.

A contact plan was drawn up that provided for staged progress to unsupervised contact and eventually overnight stays dependent on the father’s engagement with psychotherapy, with a review after 9 months.

The father appealed, challenging:

  • the evaluation of risk
    the conclusions as to his narcissistic personality traits.

The appeal court considered that the risk analysis had been properly carried out, and that the judge had made his decisions by focusing on the father's behaviour that had led to the emotional abuse, not upon a psychiatric label that might have been applied.

View the summary of the judgment on Family Law Week.