ABSTRACT
Re S (Minors) (Access) (1990) CA H and W married in 1980 and separated in 1986. There were two children, aged six and nine. An interim custody order had been issued but access proved difficult because W was terrified of H, who, she alleged, had beaten her. In 1988 one of the children, X, was handed over to H. He then applied for custody of X and the other child, Y. The judge refused an application for transfer of care and control of Y to H because of the possible upset of the child’s life. No access order was made. H appealed.
