(Court of Appeal; Thorpe, Wall and Rimer LJJ; 13 January 2010)
The child was aged 3. The English father had been living in Panama and the Lithuanian mother was living in England. The mother made allegations of violence and alcohol abuse against the father. A combined order for no contact of any kind with the father and a s 91(14) order was made for 5 years. The judge had relied on a 2 year old social services report stating that contact with Panamanian father was impractical because there was no means of monitoring it, although there was no findings of fact.
Held that refusal of all forms of contact was excessive, as there was no really good reason for doing so. Ordered two years of indirect contact, at end of which the father could then apply for a more direct form of contact, possibly supervised to begin with.