Judge Halts Father’s Supervised Contact With Children Amid Welfare Concerns

A family court has ruled that a father should not currently have supervised contact with his two children, finding that restarting face‑to‑face contact would pose too great a risk of emotional harm. In XR v ZP [2025], the court considered the children’s wishes, concerns about the father’s behaviour, inconsistent attempts to resume contact, and the uncertainty created by ongoing criminal proceedings. While the court acknowledged positive elements of a previous supervised session, it concluded that indirect contact was the only safe option at this stage.

Background to the Case

The proceedings concerned two children, a boy aged 11 and a girl aged 9, who live with their mother. The father had not seen them since October 2022 and argued that the mother was deliberately blocking contact. The mother denied this and said she had attempted to make contact possible, but raised concerns about the father’s behaviour and reliability, which had led her to pause contact in the past.

Cafcass Findings and Children’s Wishes

A Cafcass section 7 report prepared in 2023 recorded that both children loved their father and wished to see him. However, the report also highlighted the boy’s account of witnessing the father slap the mother, as well as information from the children’s school about the boy’s distress. Cafcass recommended that the children continue living with their mother and that the father complete a domestic abuse programme and a parenting course before contact could progress beyond supervision.

Difficulties Establishing Supervised Contact

One supervised contact session took place in December 2023. The notes from that session were positive and showed warmth and affection between the father and the children. Despite this, further sessions did not take place. The judge found that the father bore primary responsibility for the failure to establish regular contact, citing ongoing logistical issues, long gaps in communication, and periods when the father was abroad.

Further concerns arose when the father sent messages to his son via a gaming platform, telling him that the mother was preventing contact and asking him to keep the conversations secret. The court described these messages as inappropriate, not child‑focused, and emotionally harmful.

Impact of Criminal Proceedings

By the time of the final hearing, the father appeared remotely because he was on bail and required to live outside the mother’s area. The court was not asked to determine whether allegations of abuse were true, and the judge emphasised that this was not a fact‑finding hearing. However, the uncertainty created by the criminal process contributed to the risk that direct contact could start and then be disrupted again.

Outcome and Future Contact Arrangements

Balancing the children’s welfare needs, their expressed wishes, and the risks associated with the father’s circumstances, the court decided that supervised contact should not restart at this time. The existing contact order was discharged.

Instead, the father was permitted indirect contact through letters, cards, and gifts, to be passed on by a third party, with the mother retaining discretion regarding what is appropriate. All communication must remain child‑focused and avoid criticism or commentary about the dispute.

The judge confirmed that the father may apply again in the future if criminal matters are resolved and he can demonstrate consistent engagement and insight, but made final orders to conclude the long-running proceedings.

Case Details

Case: XR v ZP (Central Family Court)
Neutral citation: [2025] EWFC 408 (B)
Judge: HHJ Robertson
Date: 18 November 2025

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