Hello and welcome everybody very pleased to welcome you to today's session through data law. I'm Safta Mahmoud. So this then is session three of the four part session where I'm going through with you dealing with aspects us to enforcement of child arrangements orders and then seeing how this ties in with someone who matters on parental alienation. And you'll be aware that in the last couple of sessions and I've been spending some time with you going through the different options that are available to courts when it comes to dealing with enforcement of child arrangements. We've been talked about activity directions, conditions, committal switching. Child arrangements, talked about enforcement orders are really unpaid work and also financial compensation. We also spent some time looking at some of the other matters surrounding section use of Section 37 of the Children Act. Children being joined as parties pursuant to 16.4 costs orders and committal. What I'm going to be doing today is I'm going to be going through with you somebody elements running the concept of making Children available for context will be looking at that and some of the developing case law insofar as that's concerned. Then we're talking specifically about the guidance that the president, the family division sir Andrew McFarlane handed dance learning the Arrangements for child arrangements in light of the COVID-19 pandemic and also today I'll be spending some time going through with some of the developments so and in a case law as to parental alienation. So we're looking at some of those aspects and this cost and as the noise beneficial for both those of you representing Children and also for general family matters also. Right? So let's have a look then at first and foremost what we mean by making the child available for contact. This was a case of LW a few years ago. This was a case back in 2010 involved in a 1210 year old boy living with his father. A mother had the benefit of a child arrangements order specifying spending time with otherwise having contact with what you've been on as a contact or during those days. And she used to drive to the father's home to collect the child for contact except whenever she went. The father would say look, I'm very sorry but the child doesn't want to see you. He'd rather spend a day with me. He doesn't want to go with you mother obviously very, very upset about that. And she then subsequently applied for enforcement. A mother's argument was that the father wasn't trying hard enough, he was under due to make the child available to spend time with the mother and therefore she went for enforcement and she was able to secure both a compensation order for financial loss in terms of her petrol costs. I would tell you to contact when sadly it was to no avail when she used to return without the child. And also for father she alleged had not made the child available for contact into so far is not trying hard enough in trying to encourage a child. So even though the first instance court allowed both provisions for enforcement on appeal, the court took a different view and I called in fact said that we do need to look to see what we mean by making available for contact. And of course said that there would be no breach if a parent who is prevented from taking a child for contact is prevented from going on was delayed by some enforcing transport weather problems such as some of you may remember around this time in 2010 we had the problems with the airlines over the volcanic ash you might remember and if that was the case then that would not be a bridge because it was beyond the control of the the resident parent and a reasonable excuse could be where the person could have taken a child, but for good reason they did not because the child suddenly felt ill. For example, or the defendant taken the childhood doctor as opposed to contact in that regard. So that could be a reasonable excuse insofar as that's concerned. I hear the court did say that when we look at what it means to make a child available for contact, then the first citizens judge had overstated what the contact order provided for in terms of what the father is required to do and abroad rejected impossibility of performance as being a defense. The obligations the court said of father in terms of the person with whom the child was living with was to allow contact and to make the child available for contact. And to allow contact was to concede or to allow it to happen to make available was to put at one's disposal within one's reach. That was the obligation nor more nor less. So it wasn't to compel he wasn't to ensure it wasn't to make sure that come what may happen. It was to make available. And in practice that means for example, not booking in anything else but a child not blocking the child from God, not prevent a child from God. So making available but not too compel or to ensure in those circumstances. Having said that the case, The civil case was looked at a few years later the case of H. B. Which was a 2015 Decisions 2015 Decision which looked at the issue of amongst other things, Parental responsibility. This case involved two Children aged 14 and 16 and they father in this case or direct contact. The Children have been living with their mother and the court had allowed in direct contact as opposed to direct contact. Now the father had been provided with school reports. He visited a school And there was also a 91 14 order until the Children 18 to prohibit well to basically require permission to be sold before the father pursued any order in the future. And he appealed in the circumstances on the basis that he said that mother was not making the Children available or contact. And this is where Court here did say if you look at page 71 of judgment in particular, the court did say too often parents focus on their rights as opposed to really looking at their duties and responsibilities as far as Children are concerned. And in particular kinds of efforts to what launches his father as he was then had set out in the 2012 case where it's not about parental rights, but about parental responsibility. That was a real issue here. And where two parents share prs in this case, it will be due to your one parent to ensure that the rights of the other parent or respected for the benefit of the child. So very, very important. And therefore with that in mind, you had the President of family division at the time, Sir James Mumbi who specifically provided for these provisions in the order. So you can see here, his lordship said that what can one reasonably band not just as a matter of law, but also as a matter of natural parental obligation. And it's this the apparent whether by argument whether by persuasion, cajole, mint blandishments, even inducements, sanctions such as, for example, grand legal confiscation of mobile phones, computers, electronic equipment. You can imagine enough, for example, taking the ipad from a child, for example, or the threats for the shorter brute force or a combination of all of these. I used to do their level best to ensure compliance. And his lordship said that that's what you would expect. If you've got a child who's foolishly refusing to study for G C S E. S or A levels, he would absolutely use these different techniques, wouldn't you? Whether it's persuaded inducement sanctions, for example, you we do order that to get them to study. And his lordship said, why should we expect to be less of a parent whose rebellious teenage child is refusing to see her father? All right. So, you can see the judge here felt that it's not simply to make available in that regard, but it's very much to ensure using these techniques, of course. Combination of these techniques. But as you can appreciate, there is a limit even there isn't there? Right. Let's now have a look at what the guidance says. That the President of Families Division, Sir Andrew McFarlane handed down following on from the uh huh Impact of the COVID pandemic. As from March 2020. So, this was the coronavirus crisis guidance and compliance with family court chart arrangements. Orders as of 24 March last year. So, this is where you'll be aware that just before this gardeners was handed down, there was a lot of uncertainty amongst people as to what their position with was with child arrangements because people were unsure as to what the position was with Children, Dividing their time between two or more households. There was concern that because of the government state homes at that stage, there were only four reasons why people could leave their home and ensuring child arrangements that appeared was one of those, then. Does that mean that if the child was living with mother and was to be having contact with father and a couple of times a week, did that mean that that simply couldn't happen? Well, this is where the President did say that due to the coronavirus crisis, some parents whose Children are subject to chart arrangements, understandably, where they were very concerned about the ability to meet the requirements in these circumstances. And with that in mind, his lordship did say that this guidance that his lordship and Adan was there for guidance and only in general format in that regard. And one of the first things that the President did say is that parental responsibility of course, does rest with the parents first and foremost. And therefore they do need to try between them themselves to try and agree matters between themselves, were in the middle of course of a public health crisis. And therefore any arrangements to run may need to be in accordance with what's the child's interests need to be safe and responsible decisions. And with that in mind, the parents do of course need to abide by the government, stay at home rules issued by the government. And as you remember, when the first lockdown came into Effect in March 2020, many of you will remember that only four reasons why one could leave their home. And what about child arrangements as I mentioned? So does that provide for one of the exceptions? And his Lordship did say that the stay at home who's as of 27 March dealt with That was such that the government issued a lot of guidance which don't specifically charged contact arrangements. They said that where Parents do not live in the same house or Children under 18 can be moved between our parents homes. So the President said that in fact this does create an exception to the mandatory stay at home rules in that regard, but it doesn't mean that Children must be moved between homes, even though it's permit you to do so, it doesn't mean you have to and that's where the parents do need to between themselves, exercising parental responsibility, in making sure that appropriate steps and sensible steps of them put in place going forward. So with that in mind, parents need to obviously communicate with each other. So the best way to deal with these difficult situations just to be able to communicate with each other and to come up with some practical solution between themselves, okay, And therefore didn't need to need to and if it's felt therefore that there needs to be a temporary variation of a child arrangements order. So it was felt that actually on the facts in the particular circumstances, it would be inappropriate for the child to go to the other parent in the circumstances, then there could be agreement to that effect between them in those circumstances. Saw that with the parents in agreement in exercising their parental responsibly to conclude that the arrangements should be temporarily varied, then they were free to do so in those circumstances and that should make sure that to avoid any problems going forward. Uh, it should be recorded in some kind of an old email or otherwise. So both of them knew exactly where they stood and so far as that was concerned. And if that is the case, so for example, if say the child was to be having so face to face contact with his father or her father say twice a week. But it was agreed between the two between the parents. That would be inappropriate to do that in these circumstances. Then one should be looking at setting up alternative arrangements in that regard. So that meant for example, one is looking at other forms of contact, whether it's for example face to face. So it's by facetime, WhatsApp, facetime Skype soon or the connection, then that's really what should be done in two circumstances. And one of the key things that the president did say is the message that needs to be sent in these types of circumstances is where the coronavirus restrictions cause letter of a court would be very the spirit of the order should be delivered by multi alternate arrangements. They first felt that it would be unsafe for the child to go to the household given the circumstances and the very least, a spirit of the order. She maintains that it should have been looking at alternative arrangements in that regard. But what if there is no agreement and of course many of you will appreciate that given the nature of the area that we're advising on, given that sometimes sadly the parents concern may not be in a position or may not willing two communicate with each other to that extent or trying to reach an agreement. Then what do you do in that situation where there is no agreement to temporarily vary well where they do not agree to vary the arrangements, but one parent is sufficiently concerned that they were to comply with the order. Uh It would be that against the the government guidance. Then the president said that the parent main exercising their pr then very deep arrangements unilaterally. But if they do so, for example, if the Children are living with their mother and the mother tries to agree with the father, that contact should be indirect for now. But he's not prepared to uh endorse that or agree to that. And as long as the mother feels that it's appropriate to do so in those circumstances, you can voluntarily you can unilaterally vary. But if after the event, the actions of the mother and example I've just given you are questioned by the other parent in the family court or the court. The court is likely to see whether she acted reasonably and sensibly light of the official guidance understand with evidence. So she needs to be to justify her decision. Should she decided on the facts to actually unilaterally vary the contact. Okay. And therefore if she does, she should be looking at maintaining some of the former contact in the circumstances. And the court will actually look at that to see what she didn't providing for facilitated as an alternative as far as that's concerned. So you consider the thinking behind that. Now there has been some other guidance which was handed down earlier this year which is worth looking at this was body has commons library. I put the length there freeze. It's worth reading that this was the briefing paper. The number here is given and it's As of 15 February 2021 is called coronavirus separated families and contact with Children and care frequently asked questions. Indeed, you can, it's a really useful document to look actually because it gives you as a poor here some kind of frequently asked questions in relation to the issue of child arrangements and particularly regarding the impact of the coronavirus on separated families and arrangements for maintenance as well as access to cure. And it gives you some useful guidance on can Children move between the homes of separated parents? It's referring to the government guidance and also the kindness of the president of family division which runs alongside this who's regarding Children quite to self isolate and quarantine and returning from abroad for example. So there's those provisions and then also how should parents comply with court orders for contact in that regards bearing in mind again, the guidance for stay at home and how a child maintenance payments impacted upon. Was the position if one wants to visit a child in a care home for example, a way for the contact centuries. Klaus what other alternatives are there to facilitate that contact? Alright, It's worth having a look at this when you get a chance right. What I now want to do is for the best part of today, I wanted to spend some time looking specifically at the position with the developing case law. In so far as parental alienation is concerned as you can imagine, there's been a number of cases over the last few years which have looked specifically at this and parental alienation. As you remember from the first session I was talking about is where through the behavior of the often a pair would care. They it is alleged off later found have coached a child her primed a child into believing or having a particular view about the other parent. Often a very negative perception about the other parent which then drives that child to then specify and stipulate that they do not wish to have any contact, direct or indirect, sometimes with the other parent and the parents who seeks contact child arrangements spending time with. Otherwise, he's arguing that the parenthood care has alienated a child has made them coach them or trying them into having these negative thoughts, perceptions about the child, about the parent and that is certainly not conducive to meeting that child's needs and in fact it's detrimental or prejudicial to the welfare. So some of the options that people are then seeking in these circumstances sometimes, but not always. There may be seeking for firstly determination to be made as to parental alienation. And secondly, in terms of remedies you may be looking to, we visit the actual contact, you're looking to even consider applications for switching of living arrangements, for example, in favor of the non resident parent. So one such case was a case of the Age parental alienation 20 19 decision handed down by mr. Justice Kane and this particular case involved a 12 year old child who Had been living with his father, saw him with his mother since Bursa, his 12 years of age had been living with his mother And this is the matter had been caught for several times. In fact, this was a 6th set of private law proceedings. And that's what you find with many of these cases you find that they would have been in court for some time. Many of these cases and father in fact applied for transfer of the child's care from child's mother to father. So he was pushing forwards which of living arrangements in his favor. Now the child had been having a relatively regular contact with his father and his paternal family which was of good quality so that had been happening and then the direct contact stopped. So the child had been having any contact with his father enough about a year or so, expert evidence was obtained on parental alienation and the court was satisfied that the father had enjoyed previously a very good relationship with a child until about a year previously where the content going to deteriorate. Uh huh. More so and the child had enjoyed a very close relationship with his paternal grandparents and also paternal relatives in that regard. But sadly that had all sorts been affected for for about a year now and like said it was expert evidence which was obtained in so far as parental alienation as for the father's living arrangements. He's living with his family and he had also secured approval from the local authority to even get a loft conversion done because he was going to be getting a new bedroom made for for for child. And also had arranged schooling for the child and the child come and live with him. The father also made it very clear that he supported contact with the mother if residents were switched on. Living good arrangements which switched in favor of the father. So you can see he was very adamant and so fast emphasizing to the court that if the living with arrangements were switched to his failure, he would be very much ensuring that the relationship with the mother was going to be maintained mother. How was very opposed to the idea of switching living with arrangements and she sought for the child two. It was continued to reside with her in the circumstances. Some other very much opposed the application in that regard and like I say, this is where the court didn't have the benefit of expert evidence and the court accepted the expert evidence which said this. The expert said that as a result of mothers alienation that she is subject to a child too. The child I was and would continue to suffer emotional and social harm. And this situation was permitted to continue. The child would then suffer adverse consequences throughout the rest of the child's life would impede on that child's ability to form meaningful and indeed any positive relationships both now and also in the future. He may even cause a child to suffer depression later on in life. So you can see it is a very strong, very concerning aspects which the expert was referring to. So the child would suffer not just ongoing because of the failure by the mother to really not well uh, encourage that level of contact with the child would therefore cease to continue to have that relationship with not only father, but also the hold of the paternal family, which was not going to affect them long term as well. And it could even cause them to suffer depression, trying life. So you can see very, very serious issues in that regard. Now, what the court then had to decide is this, what's the potential trauma that maybe cause a child if reduce which residents. So if we leave the child where they are and not moved. I mean, these are the consequences in terms of the parental alienation. The current effect of it, the more longer term effect upon the child. But if we do switch living with arrangements to father, Then of course we have to bear in mind that this child has lived all his young life so far. His 12 years of age with his mother, he was setting install school, he had an established group of friends yet many interests. He was a member of various clubs for example. And he had lived the majority of his life in this particular area and he had visited and stayed with his father in another area. So you can see those factors were all there. But of course, if one then looked at switching residents, then this would mean that he would be moving in with his father and paternal family's home as his new home, you would have to potentially settle into a new school part way through school term. So that could be an issue. You have to make new friends, potentially you have to familiarize himself within the environment and the locality. So all of those factors you can see, we're going to be big factors which obviously are not going to be easy things to deal with at all. And there was a risk of him suffering trauma. There was a risk that he may run away from his father and unbalanced. The judge had to weigh up what the possibility of that was. There was then a transition plan that was put together. So this is where independent social worker who had provided the expert evidence had actually provided a transition plan. And this was along the lines of that. The child would be accompanied by the independent social worker to after school to be then taken to the father's home. And it was felt that once that happened, it would be contrary to child's best interests for the child to have any direct contact with his mother for a period of three months because it was necessary to almost kind of wean off the child from that level of alienation for some time to enable them to establish that relationship with his father. So the court made a child arrangements order so that the child was to go and live with his father. And the aim was that he would spend time with his mother subject to three month embargo. So it was going to be in direct contact for Next three months. And then only once he had settled with his father went after a period of three months went that contact in the resume to face to face there after sort of direct contact. So in the meantime it would be in direct contact. And what would happen is once he moved in with his dad. Mhm. Turn off the rest of the paternal family would move out for a few weeks. So that for a short period of time it would be just the father of the child who would then it was hoped to be able to form a relationship that bond with each other. So it was just the two of them and then down father's family moved back into the home after a few weeks. The contact likes a good mother. There would be only indirect contact for three months. So as to enable the childhood and to climate highest with his new placement to make sure that the alienation that the child had been subjected to. B certainly dealt with by way of um reversing that it was hoped in terms of the effect it had had on the child. And the hope was that after three months, once the child was more settled, the child would then be in a better position to then be able to have that direct face to face contact with the mother. And in fact on the facts. This worked very well and the transition plan works so you can see right. It's very, very important in these types of cases, to think about getting the necessary only appropriate form of expert evidence to assist during these types of cases and to have a very clear but robust support package under transition planners in this case, there's another case the year after. So this was a case of re s parental alienation, cold transfer of primary care. This was a decision last year handed down by mister Justice Williams. And this particular case was one way involved a nine year old child. And this is one of court. One way to court once again got the benefit of independent evidence. And if you look at paragraph 63 of the judgment. This is where the court specifically looked at the effect of alienation on Children in these types of situations whereby the court did say here that when it comes to have any findings of parental alienation life out then here, the child had said that she wanted to live with her mother. But the court would did say that even though the child was saying that she reached us a relationship with her father, but she wanted to live with her mother. The court said that the child's views had to be assessed having regard to the fact that they were distorted by the prison of alienation. So who wishes and feelings where the subjective result have been exposed to harmful beliefs and practices which had led to her ordination from her father And her Henchman with her mother. And that's the thing, as I mentioned before in the first session. Sometimes we may wish to get a 16.4 appointment where we get the child joined as a party and then we get representation for them through guardian and or solicitor, but they wish them feelings. We have to then ask ourselves whether those are distorted by the effect of parental alienation upon that charter states. So that's why we have to be very care with that. And here the court did say that the child's wishes were very much distorted by the alienation that the child had been subjected to the court did on the facts here once against which residents to father. And then there was this other case which has it has made its way to the Court, not just in 2020, but also this year in 2021. This was a case which started off as A and B parental alienation number one, which was november last year. This was handed down by Mr Justice Keon As of 21st November 2020 And a case itself involved two Children 8, 11 and 14. And both of them Were subject to three applications before the court firstly father had applied for a child arrangements or to specify in living with what he saw for the Children to live with him. Mother had applied for the Children remain living with her. A mother had also applied to discharge the passport order which had prohibited mother from applying for a passport for these Children. Okay. Now at the final hearing, parties are in fact agreed, a shared care order being agreed for the Children spend equal time with each parent. Okay, So that was a defining hearing. But then mother made allegations against father, which he disputed and what then happened is some years later, the mother made these allegations that have made further allegations against father in relation to Children, where she then subsequently applied to vary the share child arrangements order which had been made. The application was refused. This is where sadly contact began to fail. So even though the child was living with mother predominantly and father was to be spending time with the child was began to fail, things began to deteriorate him further. And on one occasion the father actually even refused sorry, the father even refused to go to his father's home. And now that's when contact began to deteriorate even further and the Children then did attend contact with her father but failed to engage with him. So you can see that's where more and more evidence came to light of alienation where the mother was potentially sabotaging their relationship was alienating their Children was prime in culture. The Children into beginning to have very negative images and views about their father and this is where the facts of this case. The court did have the benefit of expert evidence. They obtained expert evidence as to prevent alienation. And I thought to instruct a jointly a psychologist in the field of parental alienation to prepare the new report. And in fact there was several agenda with poor suburb prepared in so far as this is concerned. And you had a psychologist and the psychologist and a psychologist and a psychiatrist who both provided famous reports which will pull together to provide an opinion and paragraph 30 two of the judgment is really useful because this is where his lordship set out then what the opinion and was of the experts in particular. The expert was the psychologist was of the view that he related to parental alienation. Had agreed with the psychological assessment and prognosis, which was this. This is how it was summed up first and foremost in so far as the parental alienation is concerned, both these Children would be at real risk of failing to develop a sense of self. There was a risk of depression, trust, great sense of shame and inability to secure healthy relationship. So you can see again, this was almost emphasizing the points that the expert had provided for in the case of reach age and also the we say the case that I mentioned these consequences were intergenerational. So that both Children could be at risk of suffering any nation issued with any Children they may have. So you can see this is a long term. It was very significant actually for the consequence of printer nation. We're very far reaching in that regard. They were intergenerational. There's a risk of physical emotional harm which would be dangerous to these Children that may even engage in forms of self harm. There may be unable to regulate, regulate emotions. So you can see those who are very serious issues as well. And in fact so grave with these risks of harm that the father was really so distressed as the expert gave evidence in the proceedings. So you can see how it was affecting him in the circumstances during the hearing the court did make because of the finally said, the court made of a parental alienation. And the court just like in a real page case felt that it would be appropriate for these Children's best interests, welfare best interest for the Children to maintain and have that relationship with father and paternal family. But also the assurance that the father would enable the Children to resume a relationship with their mother. And the court decided that it was in fact in the Children's welfare best interests for there to be a switch of living with. So that's exactly what happens on the court made a child arrangements order to the father in the circumstances and one which it was hoped would enable these Children and by living with their father for them then to be able to overcome the emotional psychological homage that both suffered and which they were suffering at the hands of their mother. So you can see not only would the father be meeting the Children's needs, but also by switching living with it would hopefully overcome and reduce and hopefully stimulate the emotional psychological harm these Children had always suffered and were likely to suffer. Now the case did come back to court earlier this year, so it was re and Parental Alienation # two and it came back earlier this year in february this year. So just a few months after the decision had been handed down and what happened was this as part of the plan for switching of linguine arrangements to the father, The judge had in fact set out a potential roadmap mark logue map of when the contact would restart in circumstances and the subject positive progress, how it should increase. So it's very much in line with re hates now in the sense that the Children would move in with their father of the contact that would mother would be in direct and with a view to it being direct, once there had been positive progress made. So very much like saying line with the economy, we h case that I just mentioned 2019 decisions. But sadly this was a case where the Children did in fact leave their father's home. Just literally a few days after the order had been made in november. So a few days later, both Children left their father's home Wednesday to at the home of a friend of the mother and it also became necessary for the police to be involved to assist in seeking the return of the Children to their father. So the judge did to suspend this roadmap in terms of looking at the resumption of contact with the mother and this is where the issue joined. I was raised by the mother So she sought pursuant to 16.4 for the joint to be joined, but no formal application has been lodged. And since the child arrangements had been made in favor of father, Children had only had an indirect contact by way of letter with their mother and she had sent them a letter. So you can see it wasn't that the Children had been living or move back to their mother and in fact, a contact with mother was very limited in that regard. But the court were concerned that there was no evidence that mother had acknowledged or indeed even accepted the harm that she had caused Children and of course, could see no evidence that mother was making any real progress to change whatsoever. It's very difficult to see really any contact could be resumed In these circumstances and that's for 16.4, as I mentioned earlier, the court did say that joined the Children. This stage would be contrary to their Children's welfare best interests, it would draw them into litigation. Mother had sadly used a litigation here wrongly to really for her own ends. In disregard it would move the focus away from working therapeutically. The experts settling in with the care of the father. It would be nothing short of disastrous. His lordship said, for the Children be joined here this day, you know, proceedings so it doesn't mean that you won't join Children. As I mentioned earlier in the first session, you've got to look at at what stage in the proceedings. You look at how it's going to facilitate, facilitate and help. But here on the facts. His lordship did not feel that it was appropriate to join them at this stage, and his lordship did say that the father did seek for the procedure to be concluded and to bring the litigation to an end and that the court should have confidence in the expert in terms of how the resumption of contact with mother should be done. But the court, therefore, we're not prepared to conclude and instead, would adjourn and bring the matter back. Now, the matter then came back as we age and parental alienation number three. and this again came back before Mr. Justice key. And so it was 5th of March this year. And at that hearing. What happened is the court was going to be dealing with the issue of costs which the father was seeking. So cost schedule had been filed by both the mother and the father in the circumstances because schedules have been filed in the mother's was opposing the application by the father cost to be met. But his lordship took a different view. You remember in the first session, I did say to you that in this case of enforcement and parental alienation, the court can order costs if needs be percent apart 20 eight. It's not an easy application. Member costs generally do not quality. Of course, it's not that cost follow the event generally, there is no address the costs but the court can make costs orders where they are satisfied that there's been, for example, reprehensible behavior. And here mother was arguing that she simply could not afford to pay the costs in the circumstances. But the court took a different view. They saw that mother had already retained to receive someone somewhat somewhere In the region of excess of £2 million. At the conclusion of the financial remedy proceedings, she had substantial investments in Liquid assets in excess of £200,000. She owned a flat in Moscow. Okay, I have actually a rental property in Malibu On throughout these pursuing she had solicitors and leading cancer representative, she had wealthy family in Russia who provided with support. So in fact, the court felt it was only right proper and appropriate from whether to pay the costs and on the facts, she could actually afford to pay. Therefore costs were ordered. And then finally, the matter came back to court as re And parental alienation # four On five July this year. And what happened at that hearing is the court and then finally listed a matter for final hearing. And in fact, the court did make final orders at the hearing. Because you remember the judge that the father had asked for final orders to be made and that the court should have confidence in the experts in so far as the resumption of contact with mother will be on a supervised basis. So the court, the court were invite being invited by the father to make child arrangements order living with in his favor not only for him, but also his wife. So that that way it wasn't displacing the role of the mother, but that way it would actually confirm the actual arrangement which is both of these Children were now living with their father and also their stepmother. And therefore that would give the child arrangements living with order. Would also give the stepmother parental responsibility for the child in that Children in that regard. And in fact the call when we just started, they decided that it was in the Children's welfare best interests to make the child arrangements or to specify live with in favor of the father and the stepmother. And that was what was done. And that would of course, of course give the stepmother parental responsibility also And insofar as the position would contact his concern. The court did decide at the contact between the Children and their mother going forward, was to remain on a supervised basis as recommended by the experts. And of course a lot would then depend on whether that should then change depending on the level of progress that mother was going to be making in the circumstances. Okay? So you can see there's been a number of cases so far over the years which have looked specifically at the issue of parental alienation and this recent line of authorities and be number one through to number four. You can see that these illustrate how difficult it is for courts in these circumstances to be able to make these orders. But you can see how these cases emphasized the impact of parental alienation on Children going forward. Okay? So that then brings this session to an end and then we've got one more session where I'm just going to be putting together a few more cases for you to assist and so far as the position with that looking at parental alienation enforcement. So can I thank you very much indeed for listening and I speak to you very soon. Thank you very much. Bye for now.