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LKM v NPM

[2023] EWFC 118
Dad was found to have hurt mum and the kids. The judge wants dad to go to therapy to help him be a better dad. Mum will get to decide most things for the kids, but dad will see them more gradually, starting with shorter visits while supervised. The kids are happy but need help dealing with what happened. Everyone needs some help to deal with the stress.

Key Facts

  • Twins LLA and LL (born October 23, 2014) are the subject of a child arrangements order application.
  • Father (LKM) was found to have engaged in emotional and physical abuse of the mother and children.
  • A fact-finding hearing in July 2022 resulted in serious findings of abusive behavior by the father.
  • The case involved extensive litigation, costing approximately £1 million.
  • Expert evidence was provided by a psychiatrist (Dr. Freedman) and an independent social worker (Ms. Sandrini).
  • Dr. Freedman diagnosed the father with narcissistic personality traits, while Ms. Sandrini's initial assessment was less severe.
  • The parties' positions were diametrically opposed regarding the extent of the father's abuse and the need for therapy.
  • The children expressed a desire to spend more time with their father, including overnight stays.

Legal Principles

Children Act 1989, Section 1(3): Welfare of the child is paramount.

Children Act 1989

Presumption of parental involvement.

Children Act 1989

No order principle.

Children Act 1989

Shared residence orders/shared lives with orders are guided by the child's welfare.

Case law: C (A Child) [2006] EWCA Civ 235; Re K (Shared Residence Order) [2008] EWCA Civ 526; Re A (A Child: Joint Residence/Parental Responsibility) [2008] EWCA Civ 867; Re W (Shared Residence Order) [2009] EWCA Civ 370; Re G (Shared Residence Order: Biological Mother of Donor Egg) [2014] 2 FLR 897; L-v-F (Permission to relocate: Appeal) [2017] EWCA Civ 2121

PD12J and domestic abuse guidelines are relevant.

PD12J

Outcomes

Weekday after-school contact to be unsupervised, starting immediately.

Modest risk, children's wishes, father's demonstrated improvement.

Supervision to continue for full-day contacts until the father completes 3 months of therapy with a psychiatrist.

Ongoing risk of abusive behavior until underlying personality traits are addressed.

Sole lives with order for the mother, with a Re A schedule for parental responsibility.

Lack of parental cooperation, need to minimize conflict, and protect the mother from the father's behavior.

Children to remain at their current private school.

Provides stability and support, particularly given their exposure to parental conflict and the potential for emotional vulnerability.

Father to undergo psychotherapy.

Address underlying personality traits contributing to abusive behavior.

Mother to seek therapy to cope with stress and improve objectivity.

Manage the ongoing impact of the father's behavior and the litigation.

Children to be referred to a play/art therapist.

Address the emotional consequences of exposure to abuse and parental conflict.

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