D (Change of Circumstances: Domestic Abuse Allegations) [2026] EWCA Civ 969

The Court of Appeal allowed a father’s second appeal against an order that the child move from his care to live with her mother. The first-instance decision was unjust as a result of procedural irregularity, having relied substantially on a Cafcass assessment based on the conclusion that domestic abuse had occurred, failed to consider the consequences of changing D’s home and school, and contained inadequate reasons. The appeal was allowed, and the matter remitted for rehearing.