Victoria Flowers in Re C (OCD: Parental Obstruction of Care) [2025] EWFC 261
22nd Sep 2025 | Cases
Victoria Flowers represented the local authority in Re C (OCD: Parental Obstruction of Care) [2025] EWFC 261, a highly unusual case in which a care order was granted for a young person (C) who was imminently to turn 17. This followed an earlier successful child assessment order application.
C’s diagnoses included OCD, autism, depression, anxiety, ARFID and emetophibia. She was home educated from age 7. At one time she had been bedbound in her bedroom at home with her mother managing her self-care needs and feeding her by hand. Save for a 3 day admission to hospital, she did not leave the home from January 2023 until August 2024. The threshold findings included that the mother’s ways of understanding C and interacting with her had caused harm to her development, and the father’s approach to professionals had undermined C’s own ability to trust professionals in supportive roles.
Noteworthy for future application was that the court made a non-molestation preventing the father harassing or pestering C’s residential placement, or communicating with the placement. The court accepted the local authority’s invitation to make a non-molestation order against the father in order to protect C’s placement in reliance upon Re T (A Child) (Non-Molestation Order) [2017] EWCA Civ 1889. The court concluded that these were family proceedings and there was power to make a non-molestation order. Placement stability was at risk by reason of the father’s communications, akin to the foster placement in Re T, and the father had engaged in conduct that constituted harassment.
The case also provides an interesting example of parental engagement in care proceedings, and the court’s approach to a party seeking to record proceedings. The father, who had an autism diagnosis, was a litigant in person. He had made repeated applications (40 in July alone). The court made various participation directions for his benefit, including permitting remote attendance. The father sought to audio record the final hearing, which the court had refused. The father at final hearing either indicated he was recording, or refused to confirm that he was not recording, and his remote attendance was disconnected.
Moreover, the case serves as a helpful reminder about the importance of considering ancillary orders to run in tandem with a care order. Here, the court made a section 34 order that there should be no indirect contact between C and her father, and prohibited the father from contacting C indirectly within a non-molestation order. A section 91(14) order was made against the father in respect of any applications for contact or to discharge the care order, until C turned 18.
