19/01/2026
A recent case has been published which contains some pretty useful guidance as far as caselaw goes, in establishing grounds for the refusal of supervised contact, and also the expected requirements of a DAPP equivalent course.
Case linked below.
Supervised contact risks, and subsequent refusal of the court to order it:-
The father may speak inappropriately to the children due to his lack of insight. The father did not understand the impact of the PlayStation messages upon GC nor the emails to the children. In the emails to the children, he sought to involve them in adult matters and blamed the mother for him not seeing the children;
There is an unassessed risk that the father will involve the children in the conflict or that the children will pick up on his resentment and frustration of the mother (paragraph 43);
The father has not engaged in any meaningful way with the fact that GC has reported seeing him slap the mother three times;
The father does not understand why the mother does not bring the children to the new country he is living in and is frustrated that she did not do this;
The father cannot mentalise his children’s needs and is unable to see things from their perspective which gives rise to a risk of their needs not being met which in turn could lead to risk of further emotional harm. That risk is irrespective of supervision;
There is also a further risk of inconsistency of contact which may also cause emotional harm particularly if the children feel rejected or blame themselves (paragraph 43);
Given that the father is facing trial for ABH against the mother, any contact started now may have to be stopped if he goes to prison;
The father is also under investigation for three sexual offences, unrelated to the mother, which if proceeded with may give rise to further prison sentences;
The children could inadvertently tell the father where they are living in supervised contact which could put the mother and the children at further risk of harm.
Conditions upon a DAPP (equivalent) course being accepted by the court:-
The perpetrator to admit that they are a perpetrator;
It needs to be in person, including group work, and the course should not be online;
It will be weekly for 26 weeks;
It will challenge the father on the impact of domestic abuse not only on the primary victim but the children as well;
The course facilitator should also liaise with the victim to safeguard them and to understand whether there is any on-going tension and abuse; and
It should not be done during proceedings.
