FGM-related Family Court judgments explain how judges assess medical evidence, actual risk, travel, children’s wishes and the proportionality of restrictions. These are not criminal convictions. In some cases, the court found the evidence did not justify the allegation or a continued order.
2015 · Family Court · Allegation not established
Re B and G (Children) (No 2)
Judge: Sir James Munby, President of the Family Division · 14 January 2015
[2015] EWFC 3. The court examined conflicting medical evidence about suspected FGM. It found that the local authority had not proved that the girl had undergone FGM or was at future risk. The judgment also discussed FGM as potential significant harm in family law. Lesson: medical findings must be tested carefully; an allegation must never be presented as an established offence.
Freedom Explains — why this case matters
FGM is serious harm, but a serious allegation still needs reliable evidence. Medical opinions must be tested carefully and no family’s risk should be inferred from ethnicity or community background alone.
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2018 · Court of Appeal · FGMPO travel ban set aside
Re X (A Child: FGMPO)
Judges: Irwin LJ, Moylan LJ and Asplin LJ · 31 July 2018
[2018] EWCA Civ 1825. The Court of Appeal allowed the father’s challenge to an absolute travel ban, set that part of the protection order aside and ordered a fresh hearing. It did not dismiss the underlying need to consider FGM risk. Lesson: protective orders must be necessary, proportionate and supported by findings specific to the child.
Freedom Explains — why this case matters
An absolute prohibition can be protective but is not automatically proportionate. The court must weigh the evidence about this child, the risks of travel and the effect of restrictions on family life.
Read the published Court of Appeal judgment
2019 · High Court · FGM Protection Order
Re X (FGMPO No 2)
Judge: Mr Justice Cobb · 24 July 2019
[2019] EWHC 1990 (Fam). After a Court of Appeal-ordered rehearing, Mr Justice Cobb retained protective measures but permitted one carefully controlled visit to Egypt, with the maternal grandfather, supervised arrangements and safeguards over the child’s passport. The order prohibited FGM and required the parents to prevent it. Lesson: protection can be tailored to an evidenced risk; the law does not require an automatic, indefinite travel ban.
Freedom Explains — why this case matters
The court’s tailored travel arrangements illustrate that safeguards can be specific, monitored and proportionate. A travel permission is not a finding that FGM risk never existed; it reflects the circumstances and conditions before the court.
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2024 · High Court · Prohibited Steps Order discharged
AS v Waltham Forest
Judge: Ms Justice Harris DBE · 5 November 2024
[2024] EWHC 2808 (Fam). A longstanding travel restriction originally intended to address FGM concerns was discharged. The court weighed updated expert risk evidence, the teenager’s developing autonomy and the interference with family life. Lesson: restrictions must be reviewed and proportionate. This was a Prohibited Steps Order, not an FGM criminal conviction.
Freedom Explains — why this case matters
Protection orders should not continue by inertia. As circumstances and a young person’s wishes evolve, courts and professionals may need updated evidence and a fresh assessment of whether restrictions remain justified.
Read the Judiciary’s published judgment
2025 · Family Court · FGM allegations rejected
FJ v MH (No 1 and No 2)
Judge: HHJ Vincent, sitting as a Deputy High Court Judge · Fact-finding judgment 10 March 2025; welfare judgment 2 September 2025
[2025] EWFC 282 and 283. The court did not find an alleged risk of FGM established. It concluded that applications to restrict a mother’s and her daughters’ travel were part of a pattern of coercive control by the father. Lesson: courts must assess the evidence and consider whether protection-order proceedings themselves are being misused.
Freedom Explains — why this case matters
Courts must remain alert to the misuse of safeguarding language as a means of coercion. Allegations require evidence, and the protective process itself should not become a way to control someone’s movements or relationships.
Read the published welfare judgment (No 2) · Fact-finding judgment (No 1)
2026 · High Court · FGM Protection Orders discharged
MO v FO
Judge: Mr Justin Warshaw KC, sitting as a Deputy High Court Judge · 27 July 2026
[2026] EWHC 2442 (Fam). Following examination of competing allegations about a two-year-old child, the court was not satisfied that the alleged FGM plan had occurred or that a protective order was justified. Existing orders were discharged. Lesson: even for serious safeguarding concerns, orders require an individual, evidenced risk assessment.
Freedom Explains — why this case matters
Discharging an order after examination of the evidence does not trivialise FGM. It illustrates the need for a proper evidential basis, individual risk assessment and continuing scrutiny of restrictions.
Read the published judgment
The judgments are anonymised. Do not infer or disclose children’s identities, family locations or further details beyond what publication orders permit.
