M (Children: Contact in Prison) [2024] EWCA Civ 1104.

Lord Justice Jackson reverses Mrs. Justice Lieven's ruling allowing contact with their father, imprisoned for raping their mother. This decision cautions against prioritising children’s wishes over acknowledging the emotional impact on the victim of an unrepentant abusive parent. This case ultimately highlights the need to analyse the relevant welfare checklist factors against PD12J, providing a thorough assessment and reasons to support the decision.