Skip to content

Re A (Children) (Parental Alienation) [2019] EWFC B56

Neutral citation: [2019] EWFC B56
Court: Family Court (England & Wales), sitting at Bristol (Designated Family Judge's list, Western Circuit)
Decided: 2019-09-24
Panel: His Honour Judge Stephen Wildblood QC, sitting alone (Designated Family Judge for the Western Circuit)

Why this case matters

Re A (Wildblood) is the earliest case in the modern English Family Court arc on parental alienation (Re A 2019 → Re S 2020 → Re H-N 2021 → Re C 2023 → Re Y 2026). HHJ Stephen Wildblood QC, then Designated Family Judge for the Western Circuit, used the public-interest publication of a heavily anonymised judgment to deliver a sustained warning about late identification of alienating conduct, the catastrophic consequences of a poorly planned residence transfer, and the distributed nature of professional failure across Cafcass, the local authority, the therapeutic services, the school and the court itself. The case became the operating warning of English PA practice — by the time the alienation has hardened, the family-justice toolkit has very little left to offer.

Procedural history

Long-running private-law Children Act 1989 proceedings — by the date of the published judgment the matter had run for approximately eight years over some 36 hearings involving in the order of 10 professionals (per the Centre for Social Injustice 2019 family court judgments digest). The father had repeatedly sought enforcement of contact orders; the mother had repeatedly failed to promote the children's relationship with him. An attempt to transfer residence to the father had been ordered and implemented but had failed — the children's resistance had been underestimated and the transition had been inadequately planned (the receiving school, the therapeutic team and the receiving parent had not been properly co-ordinated). By the September 2019 hearing the practical options had been substantially exhausted; the father ultimately withdrew further enforcement proceedings to spare the children further distress. HHJ Wildblood QC ordered the heavily anonymised judgment to be published in the public interest as a paradigm case of how badly wrong intractable contact / parental alienation proceedings can go.

Experts

  • Court-appointed psychologist (name not publicly stated in available materials) — Clinical / forensic psychology — instructed under FPR Part 25 in the underlying proceedings (instructed by Family Court)
  • Cafcass officer (name not publicly stated in available materials) — Children and Family Court Advisory and Support Service — children's guardian / s.7 reporter role in the underlying proceedings (instructed by Family Court)

Holding

(1) In long-running private-law children proceedings where alienating conduct is in issue, early identification by the professional network (Cafcass, local authority, therapeutic services, school and court) is essential; late intervention is, by then, often futile. (2) A transfer of residence is not a procedure to be ordered without comprehensive planning: a properly resourced transition requires the receiving parent, the school, the therapeutic team and a tailored plan addressing the children's expected reaction. (3) Where a parent is found to have engaged in conduct that is 'deeply harmful' and that will cause significant and long-term emotional harm to the children, the family court can and should so find on the balance of probabilities; but the practical remedy available will be constrained by the stage at which the case is reached. (4) The judgment is published in the public interest as a paradigm cautionary case; specific identifying details are anonymised per s.97 CA 1989.

Verbatim

judgment (paragraph reference not publicly catalogued) (en):

deeply harmful

https://www.bailii.org/ew/cases/EWFC/OJ/2019/B56.html

judgment (paragraph reference not publicly catalogued) (en):

significant and long-term emotional harm

https://www.bailii.org/ew/cases/EWFC/OJ/2019/B56.html

judgment (paragraph reference not publicly catalogued) (en):

There had been a failure here to identify the problem before the damage was done, and early intervention was essential.

https://www.bailii.org/ew/cases/EWFC/OJ/2019/B56.html

judgment (paragraph reference not publicly catalogued) (en):

it had taken too long for the emotional and psychological issues of the mother to be uncovered, such that she was able to continue to negatively influence her children throughout the proceedings

https://www.bailii.org/ew/cases/EWFC/OJ/2019/B56.html

Outcome

Heavily anonymised judgment ordered to be published in the public interest. Findings made that the mother's conduct was 'deeply harmful' and would cause significant and long-term emotional harm to the children, the cause of which lay 'squarely with the mother'. The earlier attempted transfer of residence to the father had failed; by the date of the published judgment the children's rejection of their father had become entrenched, the practical options were substantially exhausted, and the father withdrew further enforcement proceedings to spare the children additional distress. No further coercive welfare remedy was practically available on the facts.

Comparative jurisprudence

  • Re S (Parental Alienation: Cult) [2020] EWCA Civ 568 (UK-EWS) — English Court of Appeal — least-harmful welfare analysis in PA-framed proceedings; immediately succeeds Re A in the modern English arc and applies the lesson that delay corrodes the available remedies.
  • Re H-N (Children) (Domestic Abuse: Finding of Fact Hearings) [2021] EWCA Civ 448 (UK-EWS) — re-h-n-2021-ewca-civ-448 — English Court of Appeal procedural anchor on finding-of-fact hearings in private-law CA 1989 proceedings — the procedural counter-weight to Re A's 'act early' framing: act early, yes, but only after proper fact-finding on any underlying abuse allegations. Re A and Re H-N together define the modern English tension between speed of intervention and adequacy of process.
  • Re C (Parental Alienation: Instruction of Expert) [2023] EWHC 345 (Fam) (UK-EWS) — Sir Andrew McFarlane P's later guidance restricting expert psychology in PA-framed proceedings to HCPC-registered practitioner psychologists; addresses on the expert-quality flank the same diagnostic-late, diagnostic-wrong failure mode that Re A identified at the case-management level.
  • Re Y (Experts and Alienating Behaviour: The Modern Approach) [2026] EWFC 38 (UK-EWS) — re-y-2026-ewfc-38 — Closes the modern English arc. Sir Andrew McFarlane P sets aside first-instance findings of 'alienating behaviour' built on an unregulated PA-specialist report and frames the audit in language strongly evocative of Re A — 'every agency involved in these proceedings can be seen to have been at fault' (CAFCASS, the children's solicitor, the local authority and the court). Re Y is the direct intellectual descendant of Re A on the systemic-failure flank.
  • NF v AF [2025] CSOH 13 (UK-SCO) — nf-v-af-2025-csoh-13-scotland — Scottish Outer House (Lord Stuart) decision in PA-framed proceedings — Scottish counterpart on the same UK constitutional canvas in which an HCPC-registered Chartered Clinical Psychologist's unchallenged evidence supports the alienation finding, in marked contrast to the late and uncoordinated professional response audited in Re A.
  • BVerfG 17.11.2023 – 1 BvR 1076/23 (DE) — bverfg-1-bvr-1076-23-germany-2023 — German Federal Constitutional Court constitutional critique of PAS-based Sachverständigengutachten on Art. 6 Abs. 2 GG / Kindeswohl grounds. Civil-law parallel to Re A's case-management-level critique: in both jurisdictions the systemic failure is one of expert quality and timing, the doctrinal route is different (constitutional Elternrecht in Karlsruhe; Children Act welfare and case-management duty in Bristol).

Subsequent reception

See also

  • case-study:re-h-n-2021-ewca-civ-448
  • case-study:re-y-2026-ewfc-38
  • case-study:nf-v-af-2025-csoh-13-scotland
  • case-study:bverfg-1-bvr-1076-23-germany-2023
  • jurisdiction:england-and-wales
  • jurisdiction:uk-ews
  • evidence:alienating-tactics-as-child-abuse

Sources

  1. Re A (Children: Parental Alienation) [2019] EWFC B56 — judgment — https://www.bailii.org/ew/cases/EWFC/OJ/2019/B56.html (BAILII (British and Irish Legal Information Institute)) [en] — accessed 2026-05-30
  2. A (Children : Parental alienation) [2019] EWFC B56 — case page — https://www.casemine.com/judgement/uk/5dad3ec02c94e066e39aedc7 (CaseMine) [en] — accessed 2026-05-30
  3. Parklane Plowden — The court's attitude to parental alienation in 2019: too little and too late — https://www.parklaneplowden.co.uk/the-courts-attitude-to-parental-alienation-in-2019-too-little-and-too-late/ (Parklane Plowden Chambers) [en] — accessed 2026-05-30
  4. Becket Chambers — Parental alienation: the duty to identify at an early stage or risk getting it wrong — https://becket-chambers.co.uk/articles/parental-alienation-the-duty-to-identify-at-an-early-stage-or-risk-getting-it-wrong/ (Becket Chambers) [en] — accessed 2026-05-30
  5. Family Law Partners — Parental alienation: an update — https://www.familylawpartners.co.uk/blog/parental-alienation-an-update/ (Family Law Partners) [en] — accessed 2026-05-30
  6. Pennington's — 'She had a whim of iron': intractable contact disputes — https://www.penningtonslaw.com/insights/she-had-a-whim-of-iron-intractable-contact-disputes/ (Pennington's Manches Cooper) [en] — accessed 2026-05-30
  7. Stowe Family Law — Parental alienation #2: A sorry outcome — https://www.stowefamilylaw.co.uk/blog/2019/10/23/parental-alienation-a-sorry-outcome/ (Stowe Family Law) [en] — accessed 2026-05-30
  8. Centre for Social Injustice — Family Court judgments 2019 — https://www.centreforsocialinjustice.org/family-court-judgments-2019 (Centre for Social Justice) [en] — accessed 2026-05-30
  9. Centre for Social Injustice — Disastrous transfers of residence — https://www.centreforsocialinjustice.org/disastrous-transfers-of-residence (Centre for Social Justice) [en] — accessed 2026-05-30
  10. Karen Woodall — Learning From Past Mistakes? (guest post on Re A) — https://karenwoodall.blog/2020/06/16/guest-post-learning-from-past-mistakes/ (Family Separation Clinic) [en] — accessed 2026-05-30
  11. Transparency Project — Parental alienation experts — https://transparencyproject.org.uk/parental-alienation-experts/ (The Transparency Project) [en] — accessed 2026-05-30
  12. Sam King KC & Frankie Shama — A Practical Guide to Parental Alienation in Private and Public Law Children Cases (free chapter) — https://www.lawbriefpublishing.com/2022/07/free-chapter-from-a-practical-guide-to-parental-alienation-in-private-and-public-law-children-cases-by-sam-king-qc-frankie-shama/ (Law Brief Publishing) [en] — accessed 2026-05-30
  13. Local Government Lawyer — Approach in parental alienation case was 'fundamentally flawed' and every agency was at fault, Family President rules (re Re Y [2026] EWFC 38 retrospective audit of 2019-era process) — https://www.localgovernmentlawyer.co.uk/child-protection/392-children-protection-news/99842-approach-in-parental-alienation-case-was-fundamentally-flawed-and-every-agency-was-at-fault-family-president-rules (Local Government Lawyer) [en] — accessed 2026-05-30
  14. Children Act 1989 — s.97 (Privacy for children involved in certain proceedings) — https://www.legislation.gov.uk/ukpga/1989/41/section/97 (legislation.gov.uk) [en] — accessed 2026-05-30

Editorial notes

  • BAILII (https://www.bailii.org/ew/cases/EWFC/OJ/2019/B56.html) returned a bot-protection wall (HTTP 403) at retrieval time on 2026-05-30 and could not be read directly. The primary-text verification used in this entry therefore relies on the converging secondary record across Parklane Plowden (the leading contemporaneous practitioner write-up), Pennington's Manches Cooper, Stowe Family Law, Becket Chambers, the Centre for Social Justice 2019 family court judgments digest, and the AntiAlienate source MD. The verbatim_quotes set is drawn from passages that appear, in identical wording, in two or more of those independent secondary sources.
  • Decision date 2019-09-24 is corrected from the source MD's '17 October 2019' (which appears to be the publication / public-release date or a typographic transcription of the heading date on the BAILII page). 24 September 2019 is the hand-down date consistently reported across the practitioner secondary record (Centre for Social Justice digest; Stowe Family Law publication 23 October 2019 referring to a September hand-down; Family Law Hub summary). The precise hand-down date should be confirmed against the BAILII header line when bot-protection allows direct retrieval.
  • The 'every agency [at] fault' framing for which Re A is often colloquially invoked is, on the face of the publicly available material, NOT a verbatim phrase from HHJ Wildblood QC's 2019 judgment. The exact verbatim phrasing 'every agency involved in these proceedings can be seen to have been at fault' (with CAFCASS, the children's solicitor, the local authority and the court as the named agencies) is from Sir Andrew McFarlane P's 2026 retrospective audit in Re Y [2026] EWFC 38 of a 2019-era process. The verbatim_quotes array therefore deliberately does NOT include that phrase as a Re A quotation; it is correctly catalogued as a Re Y verbatim that descends intellectually from Re A's framing.
  • Subject children anonymised as 'A' per the standard EWFC convention and the heavy anonymisation HHJ Wildblood QC directed at publication. Number, ages and sex of the children are not stated on the face of the publicly available material and 'not_stated' is used per the schema enum.
  • Experts: a court-appointed psychologist and a Cafcass officer are referred to in the publicly available secondary record as having been involved in the underlying proceedings; their names are not publicly catalogued in the materials reviewed, and they are therefore listed in the experts array under the schema-required 'name' field as 'Court-appointed psychologist (name not publicly stated in available materials)' and 'Cafcass officer (name not publicly stated in available materials)' rather than fabricating identifiers. To be confirmed against the BAILII full text when retrievable.
  • The procedural-history figure of '8 years / 36 hearings / 10 professionals' is taken from the Centre for Social Injustice 2019 family court judgments digest, which is a credible secondary catalogue but has not been verified against the BAILII judgment directly at this time.
  • Counsel array is empty; the publicly available secondary record does not catalogue counsel for the parties in Re A and the BAILII front-sheet could not be retrieved.
  • Paragraph references for the verbatim quotations are not given in the publicly available secondary record (which paraphrases or quotes without paragraph citation); the paragraph fields are flagged accordingly and should be updated against the BAILII text when bot-protection allows direct retrieval.
  • Sub-citation: the BAILII path '/ew/cases/EWFC/OJ/2019/B56.html' uses 'OJ' for the Family Court (older / official judgments stream) which is the established BAILII convention for this case; the citation '[2019] EWFC B56' is the neutral citation as universally used in the practitioner record.
  • Re S [2020] EWCA Civ 568 is recorded in comparative_jurisprudence and subsequent_reception without case_study_ref pending a separate case-study entry in the AntiAlienate knowledge base.
  • The source MD attributes the substantive lessons of the case in part to the broader practitioner commentary that grew up around it (Wildblood J's 'teaching points' and the 'every agency' framing). This case-study entry preserves the doctrinal teaching but is careful to draw the line between (a) the HHJ Wildblood QC primary judgment text, (b) the Re Y [2026] retrospective audit, and (c) the practitioner gloss; the holding field reflects (a), the verbatim_quotes field is restricted to (a), the comparative_jurisprudence and subsequent_reception fields carry (b) and (c).

Author: Alan Markson.

Licensed CC BY 4.0 — AntiAlienate Knowledge. Source of truth is the sibling .json; this .md is rendered. Do not hand-edit.