F v M
The family court found that a father had subjected two former partners to coercive and controlling behaviour, describing how such abuse can be insidious and cumulative.
Facts
Two women had each been in a relationship with the same man, and had children with him. In proceedings about the children, both women alleged that he had subjected them to coercive and controlling behaviour, including isolating them, controlling their daily lives and making threats. He denied the allegations.
Legal principle
Hayden J found that the father had subjected both women to coercive and controlling behaviour. He said that coercive control is a pattern of acts designed to make a person subordinate and dependent, and that it can be insidious and difficult to identify, because each act on its own may seem trivial, but the cumulative effect is to deprive the victim of liberty and independence. He emphasised that family judges must be alert to coercive control, and should consider the whole pattern of behaviour rather than individual incidents. The judgment was relied on in Re H-N.
Related cases on domestic abuse and occupation orders
- B v B (Occupation Order) [1999] 1 FLR 715
- Chalmers v Johns [1999] 1 FLR 392
- G v G (Occupation Order: Conduct) [2000] 2 FLR 36
- Re H-N and Others (Children) (Domestic Abuse: Finding of Fact Hearings) [2021] EWCA Civ 448
- Re L (A Child) (Contact: Domestic Violence); Re V; Re M; Re H [2001] Fam 260
- Michael v Chief Constable of South Wales Police [2015] UKSC 2, [2015] AC 1732
- Nwogbe v Nwogbe [2000] 2 FLR 744
- Opuz v Turkey (2010) 50 EHRR 28
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