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Re S (Parental Alienation: Cult) — [2020] EWCA Civ 568

TL;DR. The first explicit Court of Appeal recognition of parental alienation in English law. The Court of Appeal upheld the trial judge's findings that the father had alienated the children from the mother in the context of his involvement with a high-control religious group (the cult dimension was the unusual feature; the alienation framework was the substantive holding). The case is gender-neutral authority — the targeted parent here was the mother. Operationalized further by Re C [2023] EWHC 345 (Fam).

Maintained by Alan Markson · Last reviewed: 2026-05-15 · License: CC BY 4.0

Citation

Re S (Parental Alienation: Cult) [2020] EWCA Civ 568, Court of Appeal (Civil Division), England & Wales.

Court

Court of Appeal of England & Wales (Civil Division).

Facts

The mother appealed in proceedings concerning her children, who had been alienated from her in the context of the father's involvement with a religious group exhibiting cult-like control characteristics. Trial-court findings of fact identified specific alienating behaviors and recommended significant intervention.

Holding

The Court of Appeal upheld the trial judge's findings of parental alienation and the resulting child-arrangements orders. The judgment is significant for explicitly using the "parental alienation" framework at appellate level in English law — moving beyond earlier reluctance to engage with the terminology directly.

Significance for parental alienation

  1. First explicit Court of Appeal recognition of the PA framework in English law
  2. Gender-neutral authority — the targeted parent was the mother, undermining the older cultural framing of PA as a fathers'-rights issue (consistent with Harman, Kruk & Hines 2018 finding that PA victimization is gender-symmetric)
  3. Set the foundation for Re C (Parental Alienation: Instruction of Expert) [2023] EWHC 345 (Fam) which operationalized the expert-testimony framework
  4. Aligns with ECHR Solarino (2017) — courts examining the origin of children's stated preferences

Citing posts

# Post
49 https://www.antialienate.com/blog/what-alienating-parents-tell-new-partners
51 https://www.antialienate.com/blog/documenting-parental-alienation-for-court
54 https://www.antialienate.com/blog/spotting-parental-alienation-early-warning-signs
55 https://www.antialienate.com/blog/recognizing-parental-alienation-key-signs
62 https://www.antialienate.com/blog/parental-alienation-scope-history-future
65 https://www.antialienate.com/blog/a-mothers-battle

Primary source

  • BAILII: https://www.bailii.org/ew/cases/EWCA/Civ/2020/568.html

Disclaimer

Wiki entry, not legal advice. Verify BAILII text before citing.

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