Re A (Children) [2025] EWCA Civ 1521:
Separate Representation of Gillick‑Competent Teenagers Under Extreme Undue Influence in Forced Marriage Proceedings

1. Introduction

Re A (Children) [2025] EWCA Civ 1521 is a significant Court of Appeal decision on the separate representation of older children in family proceedings, particularly in the highly sensitive context of forced marriage and travel restriction measures.

The appeal arose from a case management order made by Lieven J on 4 December 2024, refusing permission for two teenagers (A and B), aged nearly 17 and 15, to be separately represented at a three‑day hearing concerning:

passport orders preventing them from travelling; and
forced marriage protection orders (FMPOs) lasting until they were 21.

The family is of Afghan origin, with ongoing ties to Afghanistan. There had already been three sets of proceedings under the Forced Marriage (Civil Protection) Act 2007, following:

a forced marriage of the eldest daughter in Afghanistan at 16/17; and
a later marriage of a third child (then 17) in Afghanistan despite earlier court‑based educative work, accompanied by serious findings of extreme undue influence exerted by the parents.

In the third set of proceedings – the present case – the local authority sought to control the passports of the youngest three children and to secure long‑lasting FMPOs. The two younger teenagers wished to be represented by a firm of solicitors (Goodman Ray), separately from their children's guardian appointed by CAFCASS, who was actively seeking orders to which they objected.

The first‑instance judge accepted that A and B were:

Gillick competent,
intelligent, and
able to understand the issues.

However, she refused separate representation on the basis that the children were subject to the most extreme level of parental undue influence and coercion, making it difficult to trust their instructions. The children appealed.

The Court of Appeal allowed the appeal, set aside the refusal, and ordered that A and B be separately represented, on the condition that no adjournment of the imminent substantive hearing would be sought. The judgment is framed as a procedural decision and is expressly neutral as to the outcome of the forced marriage/passport applications themselves.

The case is important because it clarifies how the courts should apply Family Procedure Rules 2010, r 16.6 in relation to older children, especially in cases involving coercion, and because it articulates a structured set of factors to be weighed when deciding whether a Gillick‑competent teenager should have separate legal representation, even where there is powerful evidence of undue parental influence.

2. Summary of the Judgment

2.1 The procedural issue

The single question on appeal was whether the judge had been wrong in refusing A and B permission to be separately represented at the forthcoming hearing considering:

passport orders for both parents and the three youngest children;
extension of existing FMPOs for A and B to the age of 21; and
a new FMPO for their older sibling C to the age of 21.

The children wished to instruct Goodman Ray. Their existing solicitor, acting for them through the guardian, was not prepared to transfer the legal aid certificate without a court order, given the assessment (shared with the guardian) that the children remained under very severe parental pressure.

2.2 Legal framework

The application fell to be decided under FPR 2010, r 16.6, which governs separate representation of children. The key test in r 16.6(6) is whether the court:

“considers that the child has sufficient understanding to conduct the proceedings concerned or proposed without a litigation friend or children’s guardian.”

The Court of Appeal reiterated the established line of authority, particularly:

W (A Child) [2016] EWCA Civ 1051; [2017] 1 WLR 1027; and
Re C (Child: Ability to Instruct Solicitor); Practice Note [2023] EWCA Civ 889; [2023] 1 WLR 4065,

emphasising that:

“the question will be: Does this child have the ability to instruct a solicitor in the particular circumstances of the case, having regard to their understanding? The assessment will be based on a broad consideration of all relevant factors... The assessment will be case specific. It will not be driven by welfare factors, or by a theoretical comparison between protection and autonomy, but by a practical assessment of the child's understanding in the particular context of the case.”

2.3 Grounds of appeal and central complaint

Seven grounds of appeal were advanced. Their “nub” was that the judge:

had focused almost exclusively on the finding of extreme undue influence, and
had failed to undertake the necessary all‑round assessment of all relevant factors bearing on the children’s ability to instruct solicitors.

Reliance was placed on Mabon v Mabon [2005] EWCA Civ 634; [2005] 2 FLR 1011, which signalled a “growing recognition of children’s autonomy”, aligned with Article 12 of the UN Convention on the Rights of the Child (UNCRC), requiring that children capable of forming views be given the right to express those views freely in all matters affecting them.

2.4 The Court of Appeal’s decision

Although acknowledging the considerable experience of the first‑instance judge with this family, and the usual reluctance to interfere with case management decisions, the Court of Appeal concluded that:

the judge had not carried out the necessary “all‑round assessment” of relevant factors; and
her decision could not stand.

The Court of Appeal remade the decision and granted A and B's application for separate representation, emphasising:

the seriousness and long duration of the potential orders;
the conflict between the children’s wishes and the guardian’s applications;
the forensic value of having advocates solely representing the children’s position;
the lack of any identified negative welfare consequences of separate representation; and
the children’s ages and acknowledged competence.

The lead judgment stressed that the existence of severe undue influence was “a major feature” but did not justify excluding separate representation for these adolescents, whose understanding was “sufficient, not complete” for instruction. It was considered better for the court and for the children’s acceptance of the outcome if they were able to participate “in the way that they seek”.

2.5 Concurring judgments

Stuart‑Smith LJ agreed, underlining what he saw as the “critical feature”:

if the judge's order were allowed to stand, there would be no one responsible solely for presenting the perceptions and submissions of the children in a case of very great significance for them.

It was not sufficient, he said, to rely on the fact that the guardian would report the children’s views while at the same time pursuing an application they opposed. He further noted that:

there were no adverse welfare consequences anticipated from granting separate representation.

Whipple LJ agreed with both judgments.

3. Precedents and Framework: How Existing Law Shaped the Decision

3.1 Family Procedure Rules 2010, r 16.6

The core rule is FPR 16.6, governing when a child can conduct proceedings without a litigation friend or children's guardian. Rule 16.6(6) provides that the court must grant an application for a child to be separately represented:

“if it considers that the child has sufficient understanding to conduct the proceedings concerned or proposed without a litigation friend or children’s guardian.”

This language focuses on understanding and ability to instruct, not on a general welfare balancing exercise. However, welfare or protection considerations can still be relevant as part of the contextual assessment – for example, if separate representation would itself pose risks or cause harm.

3.2 W (A Child) and the “understanding” test

The court reiterated the guidance from W (A Child) [2016] EWCA Civ 1051; [2017] 1 WLR 1027, where Black LJ explained that a child’s understanding may be affected by:

“age… intelligence… emotional and/or psychological and/or psychiatric and/or physical state, language, ability, influence, etc.”

The child must:

“comprehend enough of what the case is about (without being expected to display too sophisticated an understanding)”; and
“have the capacity to give his or her own coherent instructions without being more than usually inconsistent.”

This flexible, fact‑sensitive test is notable in three respects:

Non‑prescriptive and case‑specific: There is no rigid age threshold or presumption. The question is whether this child, in this case, can understand enough and give coherent instructions.
Influence is relevant but not disqualifying: “Influence” is expressly listed as a factor that may affect understanding. It is something to be weighed, not a bar in itself.
Standard of understanding: The child need not grasp every nuance; “sufficient” and “not too sophisticated” understanding is enough.

3.3 Re C (Child: Ability to Instruct Solicitor); Practice Note [2023]

In Re C (Child: Ability to Instruct Solicitor) [2023] EWCA Civ 889; [2023] 1 WLR 4065, the Court of Appeal provided a synthesised statement of principle, which was expressly quoted and adopted in Re A. The key points drawn upon were:

The core question is whether the child has the ability to instruct a solicitor in the particular circumstances of the case, having regard to their understanding.
The assessment should be based on a “broad consideration of all relevant factors”, including opinions from solicitors and experts.
The assessment is not driven by welfare factors, nor by an abstract “protection versus autonomy” debate, but by a practical assessment of the child’s understanding in context.
There are no presumptions, and no single factor should be over‑valued.

Re A follows Re C in insisting on an all‑round, multi‑factor assessment. The Court of Appeal’s core criticism of Lieven J was that she had focused too heavily on one factor – extreme undue influence – at the expense of other key considerations.

3.4 Mabon v Mabon and the autonomy of older children

In Mabon v Mabon [2005] EWCA Civ 634; [2005] 2 FLR 1011, the Court of Appeal dealt with residence and contact disputes where teenage children wished to be separately represented, adopting positions contrary to their guardian and parents. The court allowed separate representation, emphasising:

the growing recognition of children’s autonomy, especially adolescents;
the importance of Article 12 UNCRC, which requires that children capable of forming their own views be given the right to express those views freely and have them given due weight; and
the risk that children may perceive proceedings as unfair if their views are only second‑hand, filtered through adults with different objectives.

Re A explicitly cites Mabon as part of the continuing move toward greater legal voice and agency for mature children. The Court of Appeal’s concern about the “perception of unfairness” when a guardian both advances a plan and is the sole conduit of the child’s opposing view is very much in the spirit of Mabon.

3.5 Article 12 UNCRC and participation rights

Although not exhaustively discussed, Re A situates itself within the same trajectory as Mabon and later authorities in recognising:

children’s rights to be heard in judicial proceedings that affect them; and
the particular importance of direct representation for older teenagers whose lives are about to, or have just, crossed the threshold into adulthood.

Orders that will bind them into their adult years – here, until 21 – make the relevance of Article 12 especially acute.

4. The Court’s Legal Reasoning

4.1 Standard of appellate review in case management decisions

The Court of Appeal expressly noted:

the order appealed from was a case management decision by a highly experienced judge;
the Court of Appeal starts with a “strong instinct” to uphold such decisions if they can be justified, even if it might itself have decided differently.

The court nevertheless intervened because it concluded that the judge had:

failed to take into account a number of material considerations; and
over‑weighted one factor – undue influence – such that the discretionary judgment was flawed in principle.

This justified appellate correction despite the normally high threshold for disturbing case management rulings.

4.2 The core legal question

The central legal question, under r 16.6, was:

Do A and B have sufficient understanding to conduct the proceedings and instruct solicitors directly, in light of all the circumstances, including the background of extreme parental undue influence?

The judge had accepted that A and B were:

“Gillick competent”;
intelligent;
understanding the nature of the proceedings.

Her refusal of separate representation therefore did not rest on a lack of cognitive or intellectual ability but on perceived inability to give independent instructions free of coercive influence.

4.3 The role of undue influence: relevant but not decisive

The first‑instance judge characterised the case as involving:

“the most extreme level of undue influence and coercion”, making it “difficult to place reliance on what the children say”.

The Court of Appeal accepted that this factor was highly relevant and “a major feature.” However:

influences (including undue influence) are already catered for in the Re W / Re C framework as part of the all‑round assessment of understanding and ability to instruct;
it does not follow that a child under significant influence cannot instruct solicitors; the question is whether they possess sufficient understanding and can give coherent instructions, even if those instructions may be shaped by family pressures.

The Court of Appeal also made a key systemic point specific to forced marriage litigation:

Forced marriage cases, by definition, involve allegations of possible or proven coercion, yet that factor alone cannot be decisive of an older child's ability to give instructions, else it is hard to see when children could ever be separately represented in such proceedings.

Put differently: if coercion automatically precluded separate representation, the very children most affected by forced marriage and travel restrictions would be denied independent advocacy, contrary to the ethos of the Forced Marriage (Civil Protection) Act and international child‑rights norms.

4.4 The seven key factors overlooked or underweighted (para 17)

The lead judgment identifies seven particular respects in which the first‑instance reasoning was deficient. These together amount to the “all‑round assessment” that should have been carried out.

4.4.1 Seriousness and long duration of the proposed orders

First, the issues were said to be of “direct importance” to the children because the applications:

sought to deprive them of their passports; and
impose FMPOs for between four and six years – extending “three years into their adulthoods”.

These are serious and long‑term intrusions into fundamental aspects of their private lives:

freedom of movement (control of passports and travel);
family life and cultural identity (potential travel to their country of origin); and
marital autonomy (protection from forced marriage, but also constraints on family arrangements abroad).

The greater the gravity and duration of the measures, especially when they extend beyond the age of 18, the stronger the justification needed to deny a nearly‑adult child direct representation in deciding them.

4.4.2 Guardian as applicant and representative: conflict and perceived unfairness

Secondly, the guardian herself had become the protagonist of the orders that A and B opposed, having:

applied for passport orders and FMPOs for all three children up to age 21.

The Court of Appeal highlighted the structural difficulty:

the same person – the guardian – would both advance the application and be the sole conduit for expressing the children's opposing wishes and feelings;
this was “likely to foster a feeling of dissatisfaction and even a perception of unfairness” in the children;
“to an observer, it might seem odd that the party making the application was also responsible for putting forward the contrary view.”

This repeats and deepens the concern in Mabon: the legitimacy of proceedings in the eyes of the child is undermined where their legal “voice” is subsumed within the advocacy of a professional who is actively arguing for a course they reject.

4.4.3 Forensic value of independent advocacy and the absence of an effective counterparty

Thirdly, the court noted the forensic advantages of having solicitors and counsel whose sole duty is to present and test the case from the children’s perspective:

The court gains access to the best possible information about the children’s views, “unfiltered by others”.
Without separate representation, there is effectively no proper counterparty to the applications advanced by the guardian and the local authority.
The judge’s assurance that she would place great weight on the children's wishes and feelings was not an adequate substitute in the absence of advocacy on their behalf.

Particularly where the court has already made serious adverse findings about the family (including the parents’ dishonesty and coercion), there is a strong argument that the children benefit from having someone able to cross‑examine and challenge assertions, rather than relying solely on being “heard” in a non‑adversarial way.

4.4.4 Inconsistency with the separate representation of sibling C

Fourth, the court asked why it was considered appropriate for the older sibling C – close in age and circumstances – to be separately represented, but not A and B. No coherent reason was given for this distinction.

Inconsistency between siblings in similar positions can:

risk arbitrary outcomes; and
undermine the internal logic of the case management decisions.

4.4.5 No identified negative welfare consequences of separate representation

Fifth, the judge failed to identify any negative welfare consequences arising from separate representation. The Court of Appeal noted:

no such detriments were suggested by counsel for the guardian or the local authority on appeal either;
this contrasted with the situation in Re C (2023), where the court did consider the welfare impact of separate representation in a different context.

Further, there were clear positive welfare benefits that were not addressed:

children are more likely to accept the outcome (even if unwelcome) if they feel their arguments were properly put and taken seriously;
separate representation can reduce feelings of alienation and mistrust in the system.

4.4.6 The “usual” expectation for older teenagers, even in emotive cases

Sixth, the Court of Appeal stressed that, although there are no legal presumptions, in practice:

children of A and B’s age (nearly 17 and 15) would “normally expect to be separately represented”, even in emotionally charged cases;
it is inherent in forced marriage litigation that allegations of coercion are present – if that alone precluded separate representation, older children would rarely, if ever, have their own lawyers in FMPO cases.

This is a powerful policy statement: coercion cannot be allowed to silence the child’s independent legal voice in the very proceedings designed to protect them from that coercion.

4.4.7 Absence of delay or cost obstacles

Seventh, there were no case‑management impediments:

arrangements for separate representation would cause no delay to the imminent hearing (a condition of the appeal succeeding was that no adjournment would be sought);
no significant additional cost was identified.

Practicality therefore weighed in favour of, not against, separate representation.

4.5 The court’s conclusion on ability to instruct

Having considered these factors, the Court of Appeal concluded that:

the judge had not conducted the requisite all‑round assessment;
when that assessment is performed, the proper conclusion is that the children do have the ability to instruct solicitors for the purposes of these proceedings.

The court reminded itself that:

a child's understanding need only be “sufficient, not complete”;
it is accepted that A and B are Gillick‑competent and able to understand the nature and consequences of the proceedings;
the court can and will remain “alert to the likelihood that their views have been influenced by their parents and older siblings” and will evaluate that in deciding how much weight to give their wishes.

In other words, the possible taint of undue influence goes:

to the weight to be given to the child’s expressed wishes; not
to the entitlement to have those wishes advocated through separate representation.

4.6 Stuart‑Smith LJ: the “critical feature”

Stuart‑Smith LJ’s concurring judgment crystallises the principled concern:

if the judge's order were allowed to stand, there would be no one responsible solely for presenting the perceptions and submissions of the children in a case of very great significance for them.

For him, it was not a sufficient answer to say:

the guardian would present the children’s views, but;
the guardian would at the same time be pursuing her own application, which the children saw as contrary to their interests.

He also emphasised, as did the lead judgment, that:

this was not a case where there were any adverse welfare consequences anticipated from separate representation.

This directly supports the emerging principle that where:

the child is of sufficient age and understanding;
their position conflicts with that of their guardian; and
no specific welfare harm will be caused by separate representation,

the court should generally facilitate independent legal advocacy on the child’s behalf.

4.7 Continued role of the guardian

The Court of Appeal was careful to stress that its decision:

“entails no criticism whatsoever” of the guardian or her solicitor, who had “conscientiously” discharged their duties;
the guardian’s input would continue to be important, but she would no longer be legally represented.

This matters practically:

the guardian still provides the court with an independent, welfare‑focussed perspective;
but the adversarial advocacy at the hearing will be between the guardian/local authority on one side and the children’s own lawyers on the other, with the judge assessing the competing arguments and evidence.

5. Impact and Implications for Future Cases

5.1 Strengthening older children’s participation rights

Re A reinforces and develops the line of cases (Mabon, Re W, Re C) which move the family justice system towards:

greater respect for the autonomy and agency of older children, particularly those in mid‑ to late adolescence;
treating them increasingly as rights‑holders and less as passive objects of protection.

In concrete terms, practitioners can expect:

a stronger presumption in practice (though not in law) that 15–17‑year‑olds who are Gillick‑competent and wish to participate directly will be allowed separate representation, especially where serious orders will run into adulthood;
courts to be more cautious about relying solely on guardians to convey the views of older teenagers, particularly where the guardian’s plan is opposed by the child.

5.2 Forced marriage and analogous protective proceedings

In the specific context of forced marriage, travel restriction, and related protective orders (including FGM protection, radicalisation cases, and certain deprivation of liberty or secure accommodation proceedings) this case has notable implications:

Coercion and undue influence – which are inherent features of such cases – cannot automatically justify denying separate representation to older children;
judges must articulate how they have balanced:
(a) findings of coercion, against
(b) the child’s age, competence, and the gravity of the measures sought.
Where orders will extend beyond age 18, the argument for allowing a nearly‑adult person direct representation is particularly strong.

Lawyers and local authorities engaged in forced marriage litigation should therefore:

anticipate and facilitate early consideration of separate representation for teenage children; and
avoid assuming that the presence of undue influence is, without more, a reason to insist on representation through a guardian alone.

5.3 Guardians and CAFCASS practice

Re A may also influence how children’s guardians and CAFCASS approach representation issues:

where the guardian’s proposed plan is in sharp conflict with the expressed wishes of a competent older child, the case for separate representation becomes powerful;
guardians should be ready to support, or at least neutrally accommodate, such applications, particularly where no specific welfare harm from separate representation can be identified;
it underlines the importance of role clarity: guardians are welfare‑focussed witnesses and advisors to the court, not proxies for litigation positions that children wish actively to contest.

5.4 Case‑management reasoning and appellate scrutiny

Although the Court of Appeal reiterates deference to case management decisions, Re A confirms that:

where a judge bases a refusal of separate representation on a single factor (such as influence) without systematically weighing countervailing considerations, appellate intervention is possible;
judgments, even brief case management rulings, should record the core factors that informed the decision to accept or deny separate representation, especially when dealing with older teens and serious long‑term orders.

5.5 Fair trial and perceptions of justice

There is a broader Article 6 ECHR and procedural justice dimension:

children are more likely to see proceedings as legitimate and to accept outcomes if they have had a genuine opportunity to participate as parties with their own advocates;
the appearance of fairness – that someone in court is solely fighting their corner – is an important part of justice, particularly when the state is imposing protective but restrictive measures.

Re A thereby contributes to the development of child‑centred procedural norms in the family justice system.

6. Complex Concepts Explained in Plain Terms

6.1 Gillick competence

“Gillick competence” comes from an important case, Gillick v West Norfolk and Wisbech AHA [1986] AC 112. It means a child under 16 who:

has enough understanding and intelligence to fully grasp what is being proposed; and
can make up their own mind about it.

In Re A, it was accepted that both children were Gillick‑competent: they understood the nature, purpose and possible consequences of the legal proceedings.

6.2 Children’s guardian

A children’s guardian is an independent professional (usually from CAFCASS) appointed by the court to:

investigate what is going on in a child’s life;
advise the court about the child’s welfare interests; and
instruct a solicitor on the child’s behalf where the child is not directly instructing the solicitor.

The guardian is not the child’s “mouthpiece” in a pure sense; the guardian exercises professional judgment about what is best for the child, even where that differs from the child's expressed wishes. In Re A, the guardian was actively pursuing orders that the children opposed.

6.3 Separate representation

“Separate representation” means:

the child has their own solicitor and, where appropriate, barrister;
those lawyers take instructions directly from the child, not via the guardian;
the lawyers’ duty is to act on the child’s instructions and best interests in the same way they would for an adult client, subject to professional rules.

This can occur:

alongside the continued involvement of a guardian (as in Re A); or
instead of a guardian, where a guardian is removed or not appointed.

6.4 Litigation friend

A litigation friend is someone (often the Official Solicitor or a family member) who conducts court proceedings on behalf of a person who is not capable of doing so themselves (for example, because they lack mental capacity or are very young).

Under r 16.6, a child with sufficient understanding does not need a litigation friend; they can instruct solicitors directly. In Re A, the Court of Appeal had already given A and B permission to pursue their appeal without a litigation friend.

6.5 Forced Marriage Protection Order (FMPO)

An FMPO is an order under the Forced Marriage (Civil Protection) Act 2007 which aims to:

prevent a forced marriage from happening; or
protect someone who has already been forced into marriage.

The court can make a wide range of orders (for example, surrendering passports, restrictions on travel, bans on certain conduct) to keep a person safe. Breach of a FMPO can have serious legal consequences, including criminal sanctions.

6.6 Passport orders

“Passport orders” in this context are orders:

requiring passports to be surrendered to the court or a party; and/or
prohibiting applications for replacement passports or travel documents.

They are commonly used in forced marriage or abduction cases to prevent a child from being taken abroad for a forced marriage or other harmful purpose.

6.7 Undue influence and coercion

“Undue influence” in family cases refers to situations where a person’s decisions or statements are not really their free choices but are heavily shaped, controlled or coerced by someone else – for example, parents exerting extreme pressure on a child in matters of marriage, religion, or travel.

In Re A, the judge had found that:

the parents had exerted “the most extreme level of undue influence and coercion” on their children;
this had affected what the children said about the past forced marriage in Afghanistan.

The Court of Appeal accepted the seriousness of this, but held that it did not automatically prevent older teenagers from being able to instruct their own solicitors.

6.8 Case management order

A case management order is an order the judge makes to manage how the case will proceed – for example:

who will be parties;
who will be represented and how;
what evidence will be allowed; and
the timetable for hearings.

The decision whether or not to allow separate representation for a child is a case management decision. Appellate courts are usually slow to interfere with such decisions unless a clear error of principle or serious injustice is shown.

7. Conclusion: Key Takeaways and Legal Significance

Re A (Children) [2025] EWCA Civ 1521 makes a clear and practical contribution to the law on children's separate representation in family proceedings, particularly in forced marriage cases.

The main points of enduring significance are:

All‑round assessment requirement
Judges must carry out – and explain – a broad, multi‑factor assessment of a child's ability to instruct solicitors under FPR r 16.6. Undue influence is an important factor but cannot be the sole or determinative reason to refuse separate representation where the child is otherwise clearly competent.
Coercion is not an automatic bar
Inherent coercion in forced marriage contexts cannot be treated as a categorical reason to deny older children separate legal representation. Otherwise, those protection proceedings would systemically exclude their intended beneficiaries from having their own voice.
Gravity and duration of orders matter
Where proposed orders are serious and long‑lasting, especially extending beyond 18, a nearly‑adult person’s right to direct participation and advocacy carries particular weight.
Conflict with the guardian’s litigation position
A key concern is where the guardian both prosecutes an application and purports to represent the wishes of a competent teenager who opposes it. This dual role risks perceptions of unfairness and undermines the child’s participation rights. In such circumstances, there is a strong case for separate representation.
No identified welfare detriment
Where separate representation does not pose any specific welfare risks, and does not delay or unduly complicate proceedings, the balance will often favour granting it for older, competent children.
Role of independent advocacy
The Court of Appeal underscores that someone must be “responsible solely for presenting the perceptions and submissions of the children” in cases of great importance to them. Separate representation serves both substantive fairness and the child's perception that justice has been done.

In sum, Re A consolidates and extends the trajectory of cases from Mabon through Re W to Re C, embedding within family procedure a robust conception of:

older children as active legal participants with voices of their own; and
courts as having a duty, so far as possible, to hear and respect those voices through appropriate legal representation.

The decision is likely to be an important point of reference in future cases involving:

forced marriage and travel restriction orders;
other protective regimes where serious, long‑term interferences are proposed; and
contested welfare decisions affecting older, Gillick‑competent children whose positions diverge from those of their guardians or other professionals.

It confirms that protecting vulnerable children from coercion does not justify by which that protection is decided. On the contrary, the court’s ability to protect is strengthened when adolescents can participate, through their own lawyers, in decisions that will shape their futures well into adulthood.

Re A (Children) [2025] EWCA Civ 1521: Separate Representation of Gillick‑Competent Teenagers Under Extreme Undue Influence in Forced Marriage Proceedings