“o) S was removed from Scotland by their mother on 11 August 2014 without the consent of TH and was in breach of orders made by the Sheriffs Court on 12, 15 and 28 August 2014.

p) The mother has told lies to professionals. Those lies were aimed at preventing the return of S to the care of his father, protecting the mother from compliance with the lawful orders made by the Scottish court and preventing professionals discovering that the mother had told lies.

q) In consequence of the findings set out above, the N and S have suffered significant emotional harm as a result of the care given to them by their mother.

r) In attempting act in compliance with orders made by the Sheriff’s Court in Scotland TH has acted only to secure the lawful return of S.

Note 1 The Office of the Procurator Fiscal has now indicated that the criminal charges against TH will not be pursued. [Back]

Note 2 On 2 March 2016 I received a letter from the solicitor acting on behalf of the mother informing me that the mother had been assaulted and threatened by ER at her home on 20 February 2015. The letter stated that ER had been arrested and charged in relation to the incident. N and S were in the property at the time.”


This is not a new topic, but it bears repeating.

Please don’t use the word ‘disclosure’ when the word ‘said’  or ‘alleged’ would do better.

AS v TH (False Allegations of Abuse) [2016] EWHC 532 (Fam) (11 March 2016)


[33] … despite the fact that the use of the term ‘disclosure’ to describe a statement or allegation of abuse made by a child has been deprecated since the Cleveland Report due to it precluding the notion that the abuse might not have occurred (see para 12.34(1)), every professional who gave evidence in this case (except the Children’s Guardian) used the term ‘disclosure’ to describe what the children had said to them).

Disclose means to make known, to cause to appear, to allow to be seen.  It has the connotation of truth.  Whether you believe the allegation or not, until the Court has determined it, it is an allegation not…

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