Parental Alienation - going to the sharp end - Re C (Parental Alienation: Instruction of Expert) [2023] EWHC 345. Part 4.

Richard Gregorian, Principal of Gregorian Emerson Family Law Solicitors, a firm with a unique legal-psychological approach to family law, responds to the Law Society Gazette article of Hannah Summers in the 24 October 2025 edition [reference is below]

This is the 4^th and last part of my article on parental alienation, following the white noise/inevitable misdirections caused by the High Court decision in OvC.  As a matter of truisms and logic (rather than simple difference of opinion), the family justice system and the Family Justice Council (FJC) have faired very poorly throughout my articles.  Quite why that should be a surprise is beyond me because, for fear of repeating myself to the point of broken record status, legal training is perhaps the least useful training to have in seeking to understand complex human beings and the reasons for and resolution of complex parental conflict.

The case of Re C appears to be the leading case on parental alienation, at least in terms of methodology of proof and instructing an expert, with no less than the President of the Family Division presiding.  So, back we are to truisms to defend against any defamation or professional disrespect.  The last time I looked (although I had to look very closely) we still had freedom of speech in this country.

Again, I will guard against confirmation bias by commenting upon the 32 page judgement as the points arise.  It may be that, at this stage (in view of the previous 3 articles) the points are repetitive and I can summarise them very briefly.  Of course, this judgement, like any other judgement, contains but a fraction of the prior facts, information, procedures and proceedings and the other elements by virtue of which the underlying family difficulties and litigation would be analysed very differently if seen through a non-legal skill set prism.  This particular judgement is one given on appeal.

• When one looks at the dramatis personae of barristers involved in the case, it is certainly very impressive. The leading lights of the current generation of family barristers-all missing the central point. Incidentally, I have never quite understood the relevance of rule 16.4 guardians, except in terms of establishing the children’s wishes and feelings, because you would think that the parents’ legal representatives are capable of raising all of the relevant points, for the judge to consider.

• The appeal relates to whether an inferior judge was right to refuse the mother’s application to reopen findings of fact, which had led to her supervised contact. That is the legal framework. Of course, it has no relevance to understanding the cause of the family’s difficulties and how to resolve them.

• One of the major legal points is whether Ms Gill, (allegedly) an unregulated psychological expert, on whose report the mother was directed to have supervised contact, should have been the court-appointed expert. In other words, apparently being regulated has some connection to relevant knowledge and skill base. It does not-the SRA proves that in the case of family solicitors, where there is absolutely no requirement for relevant training in understanding individuals caught in and the dynamics of parental conflict.  Same with the Bar Council and barristers.  Accordingly, it would be extremely disheartening to read the judgement if it seeks to compare the credibility of the ACP-UK and the HCPC as regulatory bodies and if the judgement only looks at the issue of credibility from legal doctrine.

• It is also disheartening that the President made it very clear that the factual background was not going to be at the forefront of the appeal. That means that an almost infinite number of relevant facts, with a completely different significance than arrived at through the prism of a legal skill set, will not appear in this article. That being said, I am sure sufficient will.

• There is nothing like legal proceedings commencing, immediately following parental separation, in 2014, to demonstrate that the central issue would have been parental conflict. In other words, these parties were in conflict the moment they separated, unable to resolve their emotional and psychological difficulties with each other and of the dispute between themselves, before litigation placed them into suspended animation and exacerbated those difficulties. The courts would have been dealing with 2 traumatised people in conflict for the last 11 years at least (in reality, much longer because parental conflict led to the separation).

• Internal relocation features-I suspect an expression of how the mother was dealing with conflict. Stage one of the parental alienation (blaming) matrix i.e running away.

• Parental conflict was a problem very early on because, unsurprisingly, the court order of 2015 did nothing to resolve that issue. Let’s see who breached that order-I suspect the mother because she was the one requesting a suspension of that. Accordingly stage 2 of the (blaming) parental alienation narrative, in terms of resisting the system.  Of course, her reaction to Ms Gill’s report was stage 3.

• I am extremely impressed that the court suspended the litigation to allow for therapy and conciliation. That is almost unheard of. However, therapy without a conflict resolution component is useless as many feelings are completely appropriate.  Further, I do not know how effective the therapist was or, indeed, the therapy.  However, having therapy during litigation is likely to be unsuccessful.  You cannot effect change when there is an ongoing threat.

• Now the all-important order of 25 March 2020, instructing the expert. Let’s see how defective that was
• the part 25 application was for a child psychiatrist or psychologist, as if there is no difference between the 2 skill sets
• no expertise in terms of the adult difficulties i.e. parental conflict, which was clearly the central problem.
• the instruction was in terms of parental alienation but as I have demonstrated, that is simply a subset of parental conflict. But then, this case was elevated from parental conflict to parental alienation because the mother applied to relocate, breached the original contact order and then resisted the expert’s report. Let’s hope the expert had an understanding of parental conflict.  It may not be her problem if she did not.  Having lawyers with a deficient skill set instruct an expert with another skill set is very risky-as the conflation of child psychiatrist and psychologist demonstrates
• the report was to assess the emotional needs of the children, to inform the court as to the appropriate child arrangements. The emotional needs were for the parents not to be in conflict, not something which is dealt with by a contact order. These are the type of incongruencies I see day in day out in the Family Court.  Yet, no one is spotting them.  It was stated that without such expert evidence, there would be a lacuna in the evidence.  Frankly, even with such expert evidence, there would have been a lacuna unless the emotional needs of the children were tied to the dynamic of parental conflict, both parties given the chance to engage in improving on that issue and then fingers can be pointed.

• In fact, I see that the President has raised the very point that I did i.e. between psychology and psychiatry. One of few judges who would do so. However, clearly if that expert was Ms Gill, she was neither.  So the lawyers are to blame for placing her in that unfair position.  Ms Gill’s CV was never submitted to the court and she was described as a doctor which is not the case.  She made that clear.  She is not to blame for this-the instructing lawyers are.  She should have been removed from the case with the criticism on the lawyers, not her.

• Ms Gill’s report found parental alienation by the mother against the father. I suspect both parents were guilty of that (without intent) as they were in conflict. However, the mother made the first move.  If this sounds familiar, again, look at the 2^nd case history in part one of my article (which has all 3 stages of elevating parental conflict to parental alienation i.e. internal relocation, breach of a prior court order, and resistance of judicial opinion in the later proceedings).  Of course, the question will be if both parents are guilty of parental alienation, in terms of being in conflict with each other, why did the children seek to reject the father, not the mother.  That could have been for many reasons, including the respective emotional bond/emotional availability of each parent.  Indeed, it may be that both the expert report and the (future) FJC 3 component test for parental alienation were engaged in the sense of looking at the vertical parental dynamics between the parents and the children.  However, I still see nothing about the respective conflict resolution abilities of each parent.  The mother may have been far worse in engaging in the parental conflict, demonstrated that more openly to the children, through words or behaviour/levels of anxiety which then led to them “siding” with her.  Again, the answer to that would have been to address issues of parental conflict, not, only, how that parental conflict impacted the relationship between the children and each parent.  That is to put the children in a position of reliable objectivity in the process of blaming one parent for parental alienation, when the children are caught in conflict and are seeking to align with each parent.  This dynamic is not parental alienation, with intent, but rather the impact of parental conflict on both parents and the children.  That part of the instruction to the expert would not have been present.  It is a product of my tripartite skill set, the least important of which is being a family lawyer, with the most important being an understanding of conflict resolution and mental health.  So at this stage, we have a fundamental misdirection.  This may be seen as an attack on the expert report but then, again, no one asked her to look at the issue of parental conflict, when the lawyers were having difficulty understanding the difference between a psychiatrist and psychologist.  I have no doubt that, by this stage, in both these proceedings and the prior proceedings, there would have been numerous warnings of parental conflict by Cafcass and the courts and, yet, where was the help for that.  It may have been in that therapy but it may not have been.

• So I have absolutely no “beef” with the court-appointed expert in finding that the children were alienated from the father. But that does not mean the mother was guilty of intentional parental alienation. It may not even be parental alienation, in the sense it is understood and, certainly, not a syndrome.  It could quite easily have been a matter of joint parental conflict impacting upon the children.  After all, the court has heard of divided loyalties hasn’t it?  The court has heard of children saying goodbye to the parent dropping them off behind the garden hedge and out of sight of the other, without concluding it is parental alienation.

• With all due respect, removing the children four days after that report was concluded was a mistake. I agree it may have been designed to limit the damage on the children of the mother’s behaviour. However, what if the mother had found herself in the position she did because she was completely unsupported by the legal system in terms of understanding why she acted the way she did.  I have had many parents, mostly mothers, who seek to convince me there has been domestic abuse (nonphysical), narcissism, and/or parental alienation by the other parent.  Upon taking a detailed “therapeutic” case history, it is clear that parental conflict and feelings of threat are the problem.  Even the most educated (and legally qualified) parents fall foul of this lack of understanding about conflict/confirmation bias/cognitive dissonance.  The difficulty is in this day and age that the hundreds of pages of WhatsApp messages may not show any of that but when the relationship comes to an end, with its inevitable feelings of loss, rejection, upset et cetera, fuelled perhaps by a visit to Women’s Aid or friends and family who validate their feelings, without even having met the other parent, it is a very short route to begin blaming the other party for targeting and abusing them.  But, then again, I am speaking a foreign language to family lawyers, as they have no training in this area.  Tell this to a decent psychologist or conflict resolution expert and they will shrug their shoulders and say “Of course”.  Ms Gill may have been that mental health professional.  But then, I have to struggle in every case to ensure the expert is properly instructed to consider all relevant matters of parental conflict, even to the point where, in one of my cases, a very resistant judge was trying to prevent the psychiatrist from being involved or for them being called to court, prior to the report even having been prepared, because I took the judge to the far perimeters of their mental health and conflict resolution skill set.

• Certainly, at a very early stage, the courts were doing nothing to prevent what appeared to be a catastrophic outcome i.e. children being removed from mother and one of them from the father. I can guarantee this outcome would not have occurred with me, unless having been supported fully in understanding their share of responsibility for the joint parental conflict, both therapeutically and educatively, she was unwilling to listen. High conflict can create that resistance, as much as mental disorders, such as narcissism.   But what we do not know is how many years this conflict has been ongoing for, how the parents had resolved the disputes during their marriage, if at all and what, if any, help they had received for the impact of this escalating conflict on themselves.  For all I know, the mother could have been more reactive, the father more conflict avoidant, which would put the mother in danger of being seen to be the parental alienator.

• According to the judgement, one aspect of proving the mother was a parental alienator (which has nothing to do with the expert report) is her inability to articulate herself in a credible way in the witness box. There are many reasons for that. They can go to the emotional resilience of the mother, her ability to articulate herself under pressure or her ability to consider the matter objectively.  However, in assessing her from the witness box, the real reason for her difficulties in being reliable or credible have not been truly understood.  That is, unless you believe that understanding someone’s communication and state of mind is best achieved through aggressive cross-examination, undermining and under pressure from the witness box.  This is where we see that the law is a construct because the mother’s culpability for parental alienation is only as good as her credibility as a witness and that of the expert’s instructions, amongst many other factors.

• In terms of the children being found to have been influenced and encouraged to think negatively of their father, that may have been true in terms of the report. However, was the question of intent and why the mother acted the way she did, ever scrutinised? Could it even have taken a first breath, where the legal system looks at behaviour and intent as if inextricably and consistently linked, when they are not.

• It is interesting to note that the guardian’s independent analysis, in favour of supervised contact, was viewed as being compelling, even though it would seem that Ms Gill, as a court-appointed expert, is carrying the burden of criticism on her shoulders in terms of the mother’s supervised contact. However, the guardian would also not have been an expert in conflict resolution, able to understand the educative and therapeutic difficulties that each of the parents may have had in terms of engaging in the conflict. Perhaps another short case study: early on in my career, a father said that he had lost contact with his child because he had said nothing in court.  He said the judge felt that he did not care.  In fact, he told me he had never been exposed to conflict because his parents never argued.  He was completely bamboozled by the entire environment of conflict which he experienced in the Family Court.  I have as many unique reasons for why what appears on the surface of the conflict cannot be a reliable indicator as to what motivates that behaviour, as I have clients and their former spouses or partners.

• The mother appealed the fact-finding unsuccessfully. That is hardly surprising as it would be like appealing something which had not been considered and indeed was undermining of the legal prism through which the family justice system viewed the family’s difficulties. Apparently one of those appeal points was that Ms Gill held herself out to be a psychologist.  I have not seen any evidence of that, apart from the fact that she was not asked to produce a CV (which would have demonstrated extensive experience of reporting in parental alienation cases according to the judgement) and she never held herself out to be a doctor-in a process which the President described as lacking necessary rigour by the lawyers.  It may be relevant to note that the word “psychologist” is not protected and can be used by anyone.  Indeed, on appeal, the judge emphasised that both sets of lawyers had agreed to Ms Gill’s involvement.

• It seems that the mother could not be persuaded that her supervised contact was not the “fault” of Ms Gill, even though she was appointed and gave testimony with the agreement of both parties, had not been requested to provide a CV and it was clear that she was not claiming any medical doctorate. That being said, as a court-appointed expert, caught by the rules of FPR part 25, should she have declared she was not qualified to opine on parental alienation. That brings into focus the question whether she was not, in fact, qualified.  After all, the courts said that parental alienation is not a syndrome, and can be determined on the superficial facts and behaviours.  That means that virtually anyone with reasonable intelligence (enough to see that a child is rejecting the father), could detect parental alienation.  However, it would take a suitably qualified expert (in adult parental conflict) to understand why.  I have no doubt that the children were being alienated by both parents and I agree that the impact on the children is fundamental but it can occur without any intent whatsoever by the parents as a direct result of the parental conflict.  Ms Gill’s letter of instruction did not request such an adult assessment.  So it would appear another joint instruction, drafted by lawyers, is defective, at least in part. 

• It is interesting to note that the guardian also objected to the mother reopening her supervised contact. That engaged the legal test of whether a court should reopen findings which does not concern us here.

• As I continue reading, I am reassured by the fact that the judgement agrees with me that “psychologist” has no protected meaning.

• The judgement refers to the very protracted and damaging history of litigation but offers no solution to how it could have been avoided or the impact on the family minimised. It is clear that the circuit judge who presided over the prior application to overturn the supervised contact by granting a rehearing, failed to realise that no court order or agreement can address the underlying difficulty at the requisite level. Unsurprisingly, the mother continued to deny that she was a parental alienator-no doubt misconstruing that term because the court had done so in terms of identifying her as being the only source of blame and conflict which was impacting the children.

• So after many years of litigation, the mother continued that litigation by appealing, quite understandably, in view of the fact that she had supervised contact imposed upon her, for reasons which she felt unfair to the President of the Family Division. In that sense, one would expect it to be a very legalistic judgement based on the law of reopening judicial findings arrived at in prior court cases. Of course, one would expect that to include Ms Gill’s credibility because she was clearly the individual who was being blamed for the report that led to the mother’s supervised contact (notwithstanding the difficulties in blaming her set, out above).  Frankly, if I had been acting for Ms Gill, I would have said to the court “fight it out, you instructed her, she did not hold herself out to be a regulated psychologist, you could have asked for her CV, no one objected to her involvement until she produced her report.”  By analogy, if I employ a builder on the basis that he appears to be a lawyer, ultimately, is he to blame or am I?

• Indeed it does appear that the appeal was very focused on the governing bodies and the rather parochial approach of believing that being a member of a governing body equals quality or credibly. That would be like saying that a member of Resolution, who professes to deal with matters in a conciliatory way, does not escalate the conflict completely unnecessarily at the first sign of trouble. The answer is obvious.  Being a member of Resolution does not guarantee having the slightest knowledge of how to minimise conflict in legal correspondence.   Accordingly, unless anything particularly interesting comes to pass, arguing about different regulators and the impact on families’ conflict-related difficulties will simply be placed in the filing cabinet under “Misdirection”.

• It is, however, noteworthy, that the mother’s own barrister, on appeal, before the President criticised the way in which Ms Gill had been selected and appointed-the fault of the lawyers, not Ms Gill. Whether or not Ms Gill was qualified to carry out the assessment, goes far deeper than whether she was regulated by a particular body. The mother’s barrister agreed the entire process of appointing Ms Gill had been an utter mess at the most basic level e.g. confusing a psychiatrist or psychologist.  The fact that ACP-UK (seeking to protect the credibility of court-appointed expert clinical psychologists), said that the expert should have been a clinical psychologist, does not determine the helpfulness of the expert report.  It depends whether that psychologist understood the connection between parental alienation and parental conflict, from the perspective of the latter.  I have yet to meet one.  It is one thing applying clinical or legal knowledge to prove parental alienation or not, it is another to understand the reasons for it and then know what steps need to be taken to improve it.  I have found many clinical mental health professionals to hold little if any understanding of parental conflict.  It is my go to in overturning every single mental health report I have ever been faced with when it is adverse to my client’s interests.  Accordingly, you can have the most highly regarded and qualified child psychologist to be reporting on this case but the difficulty is that the problem lies with the adults-what a sickeningly basic omission.  That is why I instruct professionals who are adult and child psychologists.  Nowhere do I see any opinion from any of the barristers present that the necessary expert should have had expertise in adult psychology/adult conflict resolution. 

• I was totally right in guessing that the judgement would be an overly technical analysis of when an expert is an expert. The simple answer is whether he has the requisite training and understanding of the core skill set required in family breakdown-parental conflict, whether that be through solution focused communication conflict resolution/knowledge of conflict resolution/family therapy, which at least addresses the therapeutic aspects of that skill set. In the circumstances, it is quite ironic to read that the Family Court adopts a rigourous approach to the admission of expert evidence. The fact that an absence of regulation is conflated with pseudoscience is also disappointing.  After all, there is a body of opinion, within the legal profession, that believes that even the most highly regulated psychologist or psychiatrist practices pseudoscience and one can see that the significance of mental health professionals as experts in Family Court cases is being diminished, I suspect more for cost and delay reasons, than anything else.

• As noted in previous parts of this article, the fact that the issue of parental alienation is seen through the prism of domestic abuse is worrying. In other words, accusations of parental alienation (usually against women) are simply the product of abuse by the father. Let the President think about this.  If the mother is or perceives herself to be abused (whether rightly or wrongly), it would naturally follow that she would be alienating the father.  She would be crazy not to.  However, in the binary blaming environment of family law, the claim of parental alienation by the father is seen to be yet another act of intentional abuse.  The 2 concepts are not mutually exclusive.  I would much rather the Family Courts understand that actual abuse and perceptions of abuse are both connected to the conflict resolution abilities/coping strategies abilities of the relevant party.  You see, even this very simplistic principle, seen through the prism of law has a very different answer to if it, than if seen through the prism of conflict resolution.

• Accordingly, any memorandum or other utterance from the Family Courts is only as good as the understanding behind it. By this stage, it should be obvious what the main skill set which is lacking in the family justice system is, so, inevitably, it will not appear in the representation of a client by a solicitor or in any official guidance of the judges, however senior.

• There seems to be some type of consternation about whether Ms Gill could give a diagnosis of parental alienation which she was not qualified to do because she was not a clinical psychologist. The trouble is that the last time I looked, parental alienation was not a diagnosable condition in DSMV - TR and even if it was no psychologist is able to diagnose it (as opposed to a psychiatrist). So the entire judgement is fundamentally flawed in this respect.

• Indeed, I see that despite all the legal expertise present at that appeal (including the fact that the ACP-UK had 2 goes at finding the relevant authority), not one barrister could point to any legal authority that Ms Gill was not qualified or trained to hold herself out as a psychologist or to advise on the therapeutic intervention in the case. If I had been acting, I would have picked up the point whether she was a psychologist or clinical psychologist, but, more importantly, whether she was also an adult psychologist and, even more importantly than that, whether she had any training in issues of parental conflict. I have not yet met an expert that has all of those qualities.  I have met many that claim they have, who suddenly go absent without leave or completely reverse their expert reports, when I challenge them to look through the prism of adult parental conflict.  Despite the most visible pressure, the President did not make any finding that Ms Gill was not qualified to act as an expert psychological witness in family proceedings.

• I shall make it my job to contact all of the regulators, including Prof Wang at the ACP-UK (whose expertise in relation to any area of family law is not dealt with by the judgement) and ask them whether their members and supporters have the requisite knowledge base to opine on parental conflict. I know what the answer will be before I do so. Even if one were to claim that they did understand parental conflict, they would not be permitted by the courts to be the treating mental health/conflict resolution professional in any event.

• The Judgement does refer to one of the questions in the letter of instruction which Ms Gill was given. It states ‘1. Please undertake an assessment of the children focusing on their global functioning, intellectual, emotional, social and behavioural development and comment on any matters of concern.’

On that basis, it may have been completely correct to state that they were alienated, in the same way that children the subject of parental dispute suffer emotional and psychological harm (thankfully, that is received wisdom in the family justice system).  However, the problem comes when someone introduces intent i.e. that the mother intended to be a parental alienator.  That would have been a judicial matter.  The mother may have caused alienation in the same way that parents in conflict cause emotional and psychological harm, but not all of those parents are then dragged through the wringer like this mother clearly was.  That would have definitely been the product of the family justice system.  After all facts, alienating behaviours and the one-dimensional interpretation of intent behind those facts and behaviours are the stock in trade of the family justice system.  All of this is missed in the judgement.  Rather, it refers to the quality of the skills and expertise in observing the behaviours of parental alienation.  As a lawyer, I could do that the moment the child said I do not want to see my father.  That is not the issue.  The issue is that the impact of parental alienation is very easy to see, but the cause of it and whether it is intentional is a completely different skill set than Ms Gill had been instructed to apply.  In that sense, she is like every other expert I have seen in the family courts, aside from those instructed by me, and even then with great difficulty because, as I have said, referring to the very basic concept of parental conflict as being understood and resolved through the prism of this separate skill set, is like speaking Mandarin to the judges.  In fact, it is worse than that.  It acts to devalue the entire skill set and experience of that judge because the penny finally drops, so resistance is inevitable.

• So, rather than understand the fundamental omission in family law (but, then again, that would be to know unknown unknowns), ACP-UK drove their argument through whether Ms Gill had the ability to purchase particular psychological diagnostic tools. What a desperate misdirection that is.

• Question 8 of that letter of instruction is the pivotal one advice on therapeutic or other input for the children or parents. I have not seen her report so do not know what it says. However, if it recommends therapy for one or both parents but not the application of conflict resolution expertise then she is like every other expert I have ever come across and should not be unfairly criticised.

• So having ducked the issue, quite rightly, of whether Ms Gill was suitably qualified, in a sea of equally unqualified experts seeking to understand parental conflict dynamics, without any understanding of adult conflict, its aetiology, educative and therapeutic causation, how to address and improve the situation from the perspective of both parents, individually, and the dispute in between, the President offered guidance regarding unregulated psychologists as experts in the Family Court. I can only guess that the impact of this will be to ensure that the best quality experts are instructed by the court, notwithstanding they have not received training, just like the lawyers, in that fundamental conflict resolution skill set. Of that, the guidance is completely silent.
• the mere fact of being regulated by the governing body e.g. BPS (even SRA) does not guarantee the requisite skill set. If it did, the family justice system would not be in the state it is, of which this case is a prime example of a waste of resources in further traumatising family even before the application to reopen and appeals started.

• At the end of the judgement, the President considers parental alienation as a concept. Let’s see whether that concept is fully understood through the prism of legal expertise. Again, no opinion, simply truisms.
• Yes, as the President says, whether a parent has alienated a child is a question of fact for the court to resolve and not a diagnosis by a psychologist
• However, contrary to the judgement, the questions do not stop there. The follow-up questions are: is the only reality that the parent intended to alienate, which can only be answered by understanding what motivates people to act the way they do when in high conflict situations, exacerbated by litigation. There are many grey areas between human automatism and humans intending the consequences of their actions.  It seems that family lawyers need to be reminded of the difference between actus reus and mens rea (criminal justice concepts) or, at least, Re MC Bacon, an insolvency case that analysed the distinction between an individual’s intent and desire.  
• It follows that ACP-UK is completely wrong in stating that parental alienation is a process of manipulation of children perpetrated by one parent against the other to the extent that this definition is dependent upon intent which it would appear to be. If it is not, they of all institutions should make clear the distinction. Indeed, I would hope that, ACP-UK as a regulator of psychologists do not state that parental alienation is a question of fact, alone. If they do, they will be undermining the whole concept of psychology: that human beings do not always positively and consciously intend the consequences of their actions.
• In that context, I am very reassured by the President who states that what is important is the behaviour and its impact. However, yet again silent on understanding that behaviour can be understood otherwise than through a fact-finding on a balance of probabilities, with all of the other unhelpful legal constructs operating.

The Law Society Gazette article can be found at https://edition.pagesuite.com/html5/reader/production/default.aspx?pubname=&edid=445c50f3-d319-492e-85c4-cdfde5a2be6b&pnum=8&utm_source=gazette_newsletter&utm_medium=email&utm_campaign=Gazette+weekly+edition+24+Oct+2025_10%2f24%2f2025

O v C [2025] EWFC 334, which referred to an earlier judgement in those proceedings Re C (Parental Alienation: Instruction of Expert) [2023] EWHC 345.