Douglas Allen in MZA v FHB (No 4) (private law – supplementary welfare judgment) [2025] EWFC 277 (B)


15th Sep 2025 | Cases


Doug Allen acted for the Applicant mother, instructed through the public access scheme, in MZA v FHB (No 4) (private law – supplementary welfare judgment) [2025] EWFC 277 (B) where Judge Vincent delivered a supplementary welfare judgment in long‑running private law proceedings concerning two children, referred to as J and K, which involved relocation and contact issues following findings of domestic abuse against the father. This judgment, following earlier hearings and welfare decisions, addressed outstanding matters including the father’s contact arrangements and applications for supervision, expert reports, and judicial recusal.

The mother, now seeking reduced and supervised contact for the father, presented concerns about the father’s coercive behaviour and the children’s emotional safety. The father opposed such restrictions, promoting continued unsupervised contact, and sought additional forensic assessments and appointment of a guardian. The judge found the father’s past abuse and insufficient remorse rendered frequent unsupervised contact inappropriate and ordered reduced, supervised contact instead.

Applications for a forensic risk assessment and guardian appointment were denied, as the independent social worker’s evidence was sufficient and further assessments would undermine finality. The judge granted a section 91(14) protective filter — restricting the father’s ability to bring future applications without permission — to safeguard the family from the stress of ongoing litigation. The application for recusal was refused.

Earlier reported judgments in this case MZA v FHB (No 3) (private law – welfare judgment) [2025] EWFC 276 (B) and J (A Boy) and K (A Girl), In the Matter of (Re Children Act 1989 – Family Law Act 1996 Part IV) [2024] EWFC 77 (B).


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