Litigation Letter
Costs against recalcitrant mother
In re T (a child) [2005] EWCA Civ 311
Although after a fact-finding hearing the judge found that the mother with whom the child resided need have no concerns about
the child’s contact with its father, the mother remained obdurate and made further unfounded allegations against the father
necessitating a total of four hearings. There is a limit to which allowance could be made for a parent who deliberately and
unreasonably obstructs contact and the Court of Appeal upheld the judge’s order that the mother should pay the costs of all
four hearings.