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Children caught in the middle: parental alienation and implacably hostile parents
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Kate Molan Associate
Penningtons Manches
The use of the term 'implacably hostile' when describing a parent is not a recent development in the family courts. It is a phrase often used to describe extreme negative behaviour exhibited by one parent to undermine a child’s relationship with the other.
Many separating parents struggle to come to terms with the new dynamics and mutual respect that co-parenting apart entails. Most will promote a child’s relationship with the other parent even if at times it is difficult to set aside their own feelings as an ex-partner. Being an implacably hostile parent is much more extreme than this: the term should only be applied to a parent who will do almost anything to frustrate a relationship between the child and their other parent.
What is parental alienation?
Implacably hostile situations can often result in parental alienation. Parental alienation describes a situation where a child has been deliberately manipulated coerced or otherwise pressured to align themselves to one parent by the other. The impact on children has been recently highlighted by the Children and Family Court Advisory and Support Service (
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