Luke Eaton, instructed by Charles Mellor of Creighton and Partners, appeared for the appellant mother in the case of A Mother (Appeal: Alienating Behaviours: Fair Procedure) [2026] EWHC 783. 

In this case a Recorder had made findings at first instance against the mother of alienating behaviours and fabrication / encouragement of allegations. The mother appealed both sets of findings. 

The appeal was heard in the High Court before Mr Justice Poole. The appeal was allowed in respect of the findings of alienating behaviours and those findings were set aside. The appeal Court found that the Recorder had fallen into procedural and substantive error when making such findings, including in how he approached the relevant Family Justice Council guidance. 

The Court clarified the Recorder's findings on fabrication, including correcting the inaccurate recording of the findings within the first instance order.