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

Neutral citation: [2020] EWCA Civ 568
Court: Court of Appeal (Civil Division), on appeal from the Central Family Court (HHJ Meston QC, case ZC19P00137; appeal case B4/2020/0318)
Decided: 2020-04-29
Panel: McCombe LJ / King LJ / Peter Jackson LJ (judgment of the Court delivered by Peter Jackson LJ)

Why this case matters

Re S [2020] EWCA Civ 568 is the leading English Court of Appeal statement on judicial response to parental alienation findings, delivered by Peter Jackson LJ with McCombe and King LJJ agreeing. It holds that once a court finds that a process of alienation has begun, the obligation is to respond with 'exceptional diligence' and to take 'effective measures' rather than to retreat to the line of least resistance. It also expands the conceptual frame of 'alienating behaviour' beyond direct denigration to include immersion in a high-control group whose totalising worldview pathologises the rejected parent. The case sits in the modern English arc Re A (2019) → Re S (2020) → Re H-N (2021) → Re C (2023) → Re Y (2026): Re H-N anchors fact-finding on the abuse side, Re C and Re Y regulate expert quality, and Re S is the authority for the proposition that judicial findings of alienation must be matched by judicial action.

Procedural history

Father's application under s.8 Children Act 1989 to vary a shared-care child arrangements order so that the 9-year-old subject child would live primarily with him. The parties separated when the child was approximately one year old. At first instance HHJ Meston QC (sitting at the Central Family Court, case ZC19P00137) accepted the entirety of the father's factual case on the mother's adherence to a named Australian high-control group (held by the judge to be a cult) and on the harm to the child, including a finding that 'a process of alienation had started to occur'. Nevertheless, HHJ Meston declined to vary residence, accepting (or proposing to accept) undertakings from the mother. The father appealed; the mother sought permission to cross-appeal. The appeal was heard remotely on 25 March 2020 under the Covid-19 protocol; judgment was handed down remotely at 10:30 on 29 April 2020. The Court of Appeal allowed the father's appeal, refused the mother's application for permission to cross-appeal, and remitted the matter for early final determination by the President of the Family Division (Sir Andrew McFarlane), warning that without 'a wholesale transformation in the mother's position' the court at the further hearing was likely to find it necessary to transfer the child's care to the father. The remitted hearing became Re S (Parental Alienation: Cult: Transfer of Primary Care) [2020] EWHC 1940 (Fam), in which Williams J ordered transfer of primary care to the father.

Counsel

  • Will Tyler QC (Leading counsel (pro bono)) — instructed by Peacock & Co Solicitors for Appellant Father
  • Kate Grieve (Junior counsel (pro bono)) — instructed by Peacock & Co Solicitors for Appellant Father
  • Portia O'Connor (Counsel) — Pegasus Legal LDP for Respondent Mother

Experts

  • Helena Ware — Independent Social Worker (formerly an experienced Children's Guardian); appointed jointly to advise the court on Lara's welfare and on the mother's compliance with previous orders (instructed by jointly by the parties (and re-instructed by order of the court following the trial judgment))
  • Rev Dr David Millikan — Expert on cults and new religious movements; evidence originally given in Australian litigation and relied upon by HHJ Meston QC at first instance (instructed by evidence taken from prior Australian proceedings; relied upon at first instance)
  • Cafcass Officer (court-appointed) — Cafcass safeguarding and welfare reporting in 2017 and 2019; the Cafcass officer's identity is recorded in the court file but is not central to the appellate ratio (instructed by Cafcass / the Family Court)

Holding

(1) Where a court finds that a process of parental alienation has begun, the court is under a positive obligation to take effective measures with exceptional diligence; the line of least resistance, dressed up as caution, is itself a legal error and 'will probably reinforce the position of the stronger party at the expense of the weaker party and the bar will be raised for the next attempt at intervention' (para 13). (2) Alienation, for working purposes, is the Cafcass definition: 'When a child's resistance/hostility towards one parent is not justified and is the result of psychological manipulation by the other parent'; the manipulation 'need not be malicious or even deliberate. It is the process that matters, not the motive' (para 8). (3) Immersion of a child by one parent in a high-control belief system that pathologises the other parent's worldview can itself constitute alienating behaviour, even where there is no individualised smear campaign; the law's neutrality on belief (Re G [2012] EWCA Civ 1233) yields where the manifestation of belief causes welfare harm to the child. (4) A change of the child's main home is 'not regarded as a last resort' in alienation cases (Re L [2019] EWHC 867 (Fam)); the court must take a medium- to long-term view and not accord excessive weight to short-term disruption (Re O [1995] 2 FLR 124). (5) On the facts, HHJ Meston QC's response to his own findings — accepting bare undertakings from a mother whose adherence had persisted for almost the whole of the child's life — represented 'a clear failure to get to grips with the rooted problem'; the judge had given 'inordinate weight to the disadvantages of change' and had not taken 'effective steps to counter' the alienation he had found.

Verbatim

[8] (en):

As to alienation, we do not intend to add to the debate about labels. We agree with Sir Andrew McFarlane (see [2018] Fam Law 988) that where behaviour is abusive, protective action must be considered whether or not the behaviour arises from a syndrome or diagnosed condition. It is nevertheless necessary to identify in broad terms what we are speaking about. For working purposes, the CAFCASS definition of alienation is sufficient: 'When a child's resistance/hostility towards one parent is not justified and is the result of psychological manipulation by the other parent.' To that may be added that the manipulation of the child by the other parent need not be malicious or even deliberate. It is the process that matters, not the motive.

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

[9] (en):

Where a child's relationship with one parent is not working for no apparent good reason, signs of alienation may be found on the part of the other parent. These may include portraying the other parent in an unduly negative light to the child, suggesting that the other parent does not love the child, providing unnecessary reassurance to the child about time with the other parent, contacting the child excessively when with the other parent, and making unfounded allegations or insinuations, particularly of sexual abuse.

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

[10] (en):

Where a process of alienation is found to exist, there is a spectrum of severity and the remedy will depend upon an assessment of all aspects of the child's welfare, and not merely those that concern the relationship that may be under threat. The court's first inclination will be to reason with parents and seek to persuade them to take the right course for their child's sake, and it will only make orders when it is better than not to do so. Once orders are required, the court's powers include those provided by sections 11A to 11O of the Children Act 1989, and extend to consideration of a more fundamental revision of the arrangements for the child. We agree that whilst a change in the child's main home is a highly significant alteration in that child's circumstances, such a change is not regarded as 'a last resort': Re L (A Child) [2019] EWHC 867 (Fam) at [53] to [59] per Sir Andrew McFarlane P. The judge must consider all the circumstances and choose the best welfare solution.

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

[11] (en):

Cases at the upper end of the spectrum of alienation place exceptional demands on the court. It will recognise that the more distant the relationship with the unfavoured parent becomes, the more limited its powers become. It must take a medium to long term view and not accord excessive weight to short-term problems: Re O (Contact: Imposition of Conditions) [1995] 2 FLR 124 per Sir Thomas Bingham MR at 129. It must, in short, take action when and where it can do so to the child's advantage.

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

[13] (en):

In summary, in a situation of parental alienation the obligation on the court is to respond with exceptional diligence and take whatever effective measures are available. The situation calls for judicial resolve because the line of least resistance is likely to be less stressful for the child and for the court in the short term. But it does not represent a solution to the problem. Inaction will probably reinforce the position of the stronger party at the expense of the weaker party and the bar will be raised for the next attempt at intervention. Above all, the obligation on the court is to keep the child's medium to long term welfare at the forefront of its mind and wherever possible to uphold the child and parent's right to respect for family life before it is breached. In making its overall welfare decision the court must therefore be alert to early signs of alienation. What will amount to effective action will be a matter of judgement, but it is emphatically not necessary to wait for serious, worse still irreparable, harm to be done before appropriate action is taken. It is easier to conclude that decisive action was needed after it has become too late to take it.

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

[93] (en):

Finally on this aspect of the matter, the dismissal of the father's application at a point where the mother was yet to give any undertakings at all represented a clear failure to get to grips with the rooted problem that the judge had identified. … The inability of the court to identify undertakings that were both voluntary and sufficient should have alerted the judge to the intractable nature of the problem. In the situation that then existed, the harm arising from [the named high-control group] (both from its teachings and its divisive effect) was set to continue.

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

[94] (en):

The second way in which we consider the judge to have been in error concerns his response to his findings of alienation. Having found that a process of alienation had started to occur, he did not in our judgement take effective steps to counter it. By the time of the order of 15 January, the relationship between Lara and her father was in considerable difficulties. The court's response was to re-instruct Ms Ware to advise the parents. However, even if advice from any quarter was likely to be effective, the mother showed no sign of being amenable to receiving it from Ms Ware. The orders made following the dismissal of the father's application were not made in any recognisable proceedings and disclose no identifiable strategy for addressing the damage that was being caused to Lara's relationship with her father. There was no incentive for the mother to change her approach of laying all problems at the father's door, with time passing all the while.

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

[97] (en):

We do not find a balancing-up of these factors in the judgment. At paragraph 119 the judge simply states a firmly-reached conclusion. We infer that he found that the harm arising from a move to the father's care would outweigh all other forms of harm. In our view, that minimised the continuing and untreated harm to Lara from [the named high-control group] and from the developing parental alienation while at the same time it gave inordinate weight to the disadvantages of change designed to address the deep-seated problems within the family.

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

[101] (en):

… she has no way of understanding that a very significant contributor to this process, if it is not indeed its cause, is the mother's adherence to [the named high-control group]. It is a pervasive source of ongoing harm to Lara, emotionally and psychologically, and may make her vulnerable to eating disorders. We consider that unless decisive counter-measures are taken the influence of the belief system and the distancing of Lara from her father are likely to become entrenched as she grows older. … She views [the named high-control group] as a vital and benign entity. She has not begun to understand the substance of the judge's findings and the concerns expressed by others. That is how cults work.

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

[104] (en):

We find the arguments finely balanced. In the end, and not without hesitation, we have concluded that the risks involved in postponing a final decision are just worth taking. … With the agreement of the President of the Family Division, we shall remit the father's application for early final determination by him. By determining the matter in this way we are giving the mother a very short respite during which she will have one last chance to take her own steps to leave [the named high-control group], start intensive therapy, and reverse the process of alienation of Lara from her father. … Above all, and so that the parties are left in no doubt, we warn that we foresee that without a wholesale transformation in the mother's position the court at the further hearing is likely to find it necessary to transfer Lara's care to her father.

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

Outcome

Mother's application for permission to cross-appeal refused. Father's appeal allowed. Paragraph 4 of HHJ Meston QC's order set aside; paragraphs 11-13 replaced by the Court of Appeal's order. Matter remitted for early final determination by Sir Andrew McFarlane P (President of the Family Division) in July 2020, with an express warning that without 'a wholesale transformation in the mother's position' the court at the remitted hearing would be likely to find it necessary to transfer the child's primary care to the father. Helena Ware (Independent Social Worker) re-instructed jointly by the parties to report on the mother's response to the judgment and on child arrangements. Neither parent to change the child's home address or remove her from England and Wales pending the remitted hearing (with a warning notice). The remitted welfare hearing — heard by Williams J as Re S (Parental Alienation: Cult: Transfer of Primary Care) [2020] EWHC 1940 (Fam) on 15 July 2020 — found the mother's purported disassociation 'skin-deep rather than full-hearted' and ordered the child to live with her father, with no direct or indirect contact with the mother during the summer break.

Comparative jurisprudence

  • Re A (Children) (Parental Alienation) [2019] EWFC B56 (HHJ Wildblood QC) (UK-EWS) — re-a-2019-ewfc-b56 — Earliest of the modern English PA arc; expressly cited by Peter Jackson LJ at para 12 of Re S as a 'post mortem' example of what happens when courts fail to act on early signs of alienation (8 years of proceedings, 36 hearings, 10 professionals, no contact despite an attempted change of residence). Re S articulates the doctrinal corrective that Re A illustrates the absence of.
  • Re H-N (Children) (Domestic Abuse: Finding of Fact Hearings) [2021] EWCA Civ 448 (UK-EWS) — re-h-n-2021-ewca-civ-448 — Immediately follows Re S in the modern English arc. Re H-N (Sir Andrew McFarlane P, King LJ, Holroyde LJ) anchors the fact-finding side: allegations of domestic abuse must be properly tried on the civil standard with attention to patterns of coercive and controlling behaviour before any welfare or expert evidence on alienation is allowed to displace them. Read with Re S, the two cases bookend the doctrinal symmetry: fact-find DA properly (Re H-N); once alienation is found, act on it (Re S).
  • Re C (Parental Alienation: Instruction of Expert) [2023] EWHC 345 (Fam) (UK-EWS) — Sir Andrew McFarlane P's guidance restricting expert psychology in PA-framed proceedings to HCPC-registered practitioner psychologists; sits between Re H-N (procedural anchor) and Re Y (expert-quality remedy) and operates as the evidential gateway through which Re S-style alienation findings must now pass.
  • Re Y (Experts and Alienating Behaviour: The Modern Approach) [2026] EWFC 38 (UK-EWS) — re-y-2026-ewfc-38 — Sir Andrew McFarlane P sets aside first-instance findings of 'alienating behaviour' built on an unregulated PA specialist's report. Re S and Re Y now bookend the modern English approach: alienation findings must be earned through proper fact-finding and regulated expert evidence (Re H-N + Re C + Re Y), but once earned, they must be acted on with effective remedy (Re S).
  • F v M [2021] EWFC 4 (Hayden J) (UK-EWS) — Parallel English landmark on coercive and controlling behaviour, expressly endorsed by the Court of Appeal in Re H-N; the totalising-belief-system mechanism in Re S maps doctrinally onto the F v M coercive-control framing — the harm arises from the totalising milieu rather than discrete incidents.
  • Re L (A Child) [2019] EWHC 867 (Fam) (McFarlane P) (UK-EWS) — Expressly relied upon at para 10 of Re S for the proposition that a change in the child's main home is 'not regarded as a last resort' in alienation cases.
  • Re G (Education: Religious Upbringing) [2012] EWCA Civ 1233 (UK-EWS) — Munby LJ's leading authority on the family court's neutrality on religious and belief systems; quoted extensively at paras 4-5 of Re S. The Court of Appeal in Re S applies Re G's framework to a non-traditional high-control group and holds that the law's neutrality on belief is qualified where the manifestation of belief causes welfare harm to the child.
  • Pisica v Moldova (App. No. 23641/17) ECtHR 29 October 2019 (ECHR) — Cited at para 12 of Re S as a recent Strasbourg authority finding a breach of Article 8 ECHR for failure to act with exceptional diligence in a case of increasing alienation — the international human-rights underlay for the 'exceptional diligence' standard at para 13.
  • 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 — civil-law parallel that, conversely, polices the upstream evidential quality. Re S's effective-remedy doctrine and BVerfG's evidential-rigour doctrine together describe the two-flank European convergence: act decisively on properly-evidenced findings; do not act on PAS-labelled but methodologically unsound ones.
  • Cassazione Civ. n. 9691/2022 (IT) — cassazione-9691-2022-italy — Italian Court of Cassation requirement that PA findings rest on scientifically validated methodology — civil-law analogue to the Re S/Re C/Re Y triad: alienation findings can ground welfare remedy, but only if the underlying methodology is sound.
  • NF v AF [2025] CSOH 13 (Lord Stuart) (UK-SCO) — nf-v-af-2025-csoh-13-scotland — Scottish Outer House decision in PA-framed proceedings within the same UK constitutional space; Lord Stuart's least-harmful welfare analysis, against the evidence of a Chartered Clinical Psychologist whose evidence was 'unchallenged' (para [31]), is the Scottish doctrinal counterpart to the Re S 'effective measures' line.

Subsequent reception

See also

  • case-study:re-a-2019-ewfc-b56
  • case-study:re-h-n-2021-ewca-civ-448
  • case-study:re-y-2026-ewfc-38
  • case-study:bverfg-1-bvr-1076-23-germany-2023
  • case-study:cassazione-9691-2022-italy
  • case-study:nf-v-af-2025-csoh-13-scotland
  • jurisdiction:england-and-wales

Sources

  1. Re S (Parental Alienation: Cult) [2020] EWCA Civ 568 — BAILII listing — https://www.bailii.org/ew/cases/EWCA/Civ/2020/568.html (BAILII (British and Irish Legal Information Institute)) [en] — accessed 2026-05-30
  2. Re S (A Child) — Approved Judgment PDF (29 April 2020) — https://www.judiciary.uk/wp-content/uploads/2020/04/re-s-a-child-judgment290420.pdf (Courts and Tribunals Judiciary) [en] — accessed 2026-05-30
  3. Judiciary case page — Re S (Parental Alienation: Cult) — https://www.judiciary.uk/judgments/re-s-parental-alienation-cult/ (Courts and Tribunals Judiciary) [en] — accessed 2026-05-30
  4. Re S (Parental Alienation: Cult: Transfer of Primary Care) [2020] EWHC 1940 (Fam) — Williams J (remitted welfare hearing) — https://www.bailii.org/ew/cases/EWHC/Fam/2020/1940.html (BAILII) [en] — accessed 2026-05-30
  5. Children Act 1989 — https://www.legislation.gov.uk/ukpga/1989/41/contents (legislation.gov.uk) [en] — accessed 2026-05-30
  6. Stewarts Law — Father wins child's primary care due to mother's connection with a cult (Lucy Swinton, 3 September 2020) — https://www.stewartslaw.com/news/father-wins-childs-primary-care-due-to-mothers-connection-with-a-cult/ (Stewarts Law LLP) [en] — accessed 2026-05-30
  7. 18 St John Street Chambers — Parental alienation review: Re S [2020] EWCA Civ 568 — https://www.18sjs.com/parental-alienation-review-re-s-parental-alienation-cult-2020-ewca-civ-568-family-court-approaches-parental-alienation/ (18 St John Street Chambers) [en] — accessed 2026-05-30
  8. Law & Religion UK — Cults in the Court of Appeal: Re S — https://lawandreligionuk.com/2020/04/30/cults-in-the-court-of-appeal-re-s/ (Law & Religion UK) [en] — accessed 2026-05-30
  9. The Transparency Project — Choosing the course which is less stressful to the child — https://transparencyproject.org.uk/choosing-the-course-which-is-less-stressful-to-the-child/ (The Transparency Project) [en] — accessed 2026-05-30
  10. Re G (Education: Religious Upbringing) [2012] EWCA Civ 1233 — BAILII — https://www.bailii.org/ew/cases/EWCA/Civ/2012/1233.html (BAILII) [en] — accessed 2026-05-30
  11. Re L (A Child) [2019] EWHC 867 (Fam) (Sir Andrew McFarlane P) — BAILII — https://www.bailii.org/ew/cases/EWHC/Fam/2019/867.html (BAILII) [en] — accessed 2026-05-30
  12. Pisica v Moldova (App. No. 23641/17), ECtHR 29 October 2019 — https://hudoc.echr.coe.int/eng?i=001-197036 (European Court of Human Rights (HUDOC)) [en] — accessed 2026-05-30
  13. Family Law Journal — Sir Andrew McFarlane, 'Parental Alienation' [2018] Fam Law 988 — https://www.lexisnexis.co.uk/legal/journals/family-law (LexisNexis (Family Law Journal)) [en] — accessed 2026-05-30

Editorial notes

  • Primary verification done against the Approved Judgment PDF hosted at judiciary.uk (filename 're-s-a-child-judgment290420.pdf', 31 pages, [2020] EWCA Civ 568, Case No B4/2020/0318). BAILII (https://www.bailii.org/ew/cases/EWCA/Civ/2020/568.html) returned an Anubis bot-protection challenge wall at retrieval time on 2026-05-31 (UTC) and could not be read directly; the judgment text used for the verbatim_quotes block therefore comes from the judiciary.uk Approved Judgment PDF, which is the same Approved Judgment as the BAILII version. The source_url on each verbatim quote nevertheless points at BAILII as the canonical citation venue per AntiAlienate house style.
  • Anonymisation policy: the Court of Appeal anonymised the child (pseudonym 'Lara') and the parents (mother / father) per s.97 Children Act 1989. The Court did NOT anonymise the cult/group or its founder, both of whom were publicly named in the judgment. The AntiAlienate knowledge-base editorial policy is to redact the cult/group name in the case-study output even where the Court named it on the face of the judgment, in order to (a) keep the doctrinal frame portable across high-control-group fact patterns, (b) avoid drawing the AntiAlienate KB into the group's reputation-litigation track, and (c) honour the s.97-anonymised child whose identity is more easily reverse-engineered when the named-group fact is foregrounded. Verbatim quotes at paras 93, 97, 101 and 104 therefore substitute '[the named high-control group]' for the group's name as it appears on the face of the judgment; the original text is available at the source_url. This editorial substitution is explicitly flagged here rather than passed off as the court's own anonymisation.
  • Counsel block: Will Tyler QC and Kate Grieve appeared pro bono for the appellant father (Peacock & Co Solicitors); Portia O'Connor appeared for the respondent mother (Pegasus Legal LDP). QC suffix is retained as on the 2020 front sheet (Mr Tyler took silk before the September 2022 demise of HM Queen Elizabeth II).
  • Experts block: Helena Ware (Independent Social Worker / formerly an experienced Children's Guardian) was the central expert at first instance and was re-instructed by the Court of Appeal's remittal order. Rev Dr David Millikan (Australian expert on cults and new religious movements) is the original-instance evidential source on the group's structural character; his evidence was given in Australian proceedings (Benhayon v Rockett NSW Supreme Court, jury verdict 2018) and was relied upon by HHJ Meston QC. The Cafcass officer entry uses the institutional name rather than a personal name because the personal identity of the Cafcass officer is not load-bearing on the appellate ratio and is not foregrounded on the face of the judgment.
  • Children entry: sex 'female' is verified on the face of the judgment ('his 9-year-old daughter ... Lara' at paragraph 1); year_of_birth 2011 is verified at paragraph 14 ('Lara was born in 2011').
  • Verbatim quotes at paras 9, 10 and 11 are the working definitions of alienation and remedy that the practitioner literature most commonly cites; paras 13, 93, 94 and 97 are the doctrinal core on judicial obligation and the error in the trial judge's response; para 101 ('That is how cults work') and para 104 ('without a wholesale transformation') are the cult-context framing and the explicit warning to the remitted-hearing court respectively. These are the load-bearing passages on which the practitioner reception of Re S has rested.
  • Re A (2019) EWFC B56 is referenced under case-study:re-a-2019-ewfc-b56; this case-study slug is the AntiAlienate KB convention pending the standalone Re A case-study file being published. The Re A case is expressly cited at para 12 of Re S as a 'post mortem' example of judicial inaction.
  • Subsequent reception: Re S (Parental Alienation: Cult: Transfer of Primary Care) [2020] EWHC 1940 (Fam) — Williams J's remitted welfare ruling — is the operative outcome and is treated as the canonical follow-on rather than as a separate appellate authority.
  • Brief required cross-link to 'Family Law Journal commentary': the McFarlane LJ article '[2018] Fam Law 988' is expressly relied upon at para 8 of Re S ('We agree with Sir Andrew McFarlane (see [2018] Fam Law 988)') and is the most direct Family Law Journal commentary the judgment itself acknowledges. Direct stable URL to that article is not freely available; the publisher landing page is supplied with explicit 'unverifiable URL' flagging.
  • ECLI not assigned: the [2020] EWCA Civ 568 neutral citation is the canonical identifier; no ECLI is recorded on the face of the judgment.
  • The case is sometimes mis-cited as the work of a single judge. It is properly attributed: 'Lord Justice Peter Jackson, giving the judgment of the Court' (i.e. of McCombe LJ, King LJ and Peter Jackson LJ jointly). The judges array reflects the joint character of the judgment with Peter Jackson LJ noted as author.

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.