A judge has recommended an expert witness repay her fee to the local authority after all parties in a recent family court hearing agreed that the registered clinical psychologist’s report was “fundamentally flawed”.
1. Introduction
In the recent case of Liverpool City Council v Ms A & Ors [2025] EWHC 1474 (Fam), Dr Parsi di Landrone was appointed to conduct a psychological assessment of the father of a seven-year-old boy, as part of its assessment of whether, after three years in foster care, the child should be returned to his father’s care in Italy. The child was of dual Romanian and Italian heritage.
Di Landrone was appointed due to her being dual qualified in Italy and the UK. However, on receiving the report, all parties unanimously agreed that di Landrone had “wholly misunderstood and failed to comply with her instructions as an expert”. An alternative psychologist had to be instructed.
2. What conclusions did the expert witness reach?
One of the key issues addressed in di Landrone’s report was whether the child’s father posed a risk of domestic abuse, given that he had physically assaulted the child’s mother several years earlier.
Di Landrone concluded there was no risk - but the way in which she came to this conclusion was what challenged the integrity of her report. Rather than drawing her conclusion based on her interview with the subject of her report, she based it on her theory that the domestic abuse finding itself was wrong.
"I disagree with the finding about his violent nature in reference to the hospital record brought as evidence by [Mrs. A] as the record do not specify the name of the partner involved in that incident and [Mrs. A] was in a relationship with Mr. U as well as Mr. O at the time of the incident,” di Landrone’s report stated.
“Since Mr. O has not been charge[d] by the Italian local authority for this incident, this evidence is not an acceptable for me; especially considering that there is no further evidence that Mr. O has been violent before or after this incident or in any other romantic relationship.
“In my professional opinion, this evidence is also not acceptable as the court demonstrated that [Mrs. A] has res[orted] to lying and manipulate facts according to her benefit and the partner she chose in such circumstances […]. Ultimately, it is clear that the competitions and animosity between the fathers fueled by the ambiguous and enmeshed behaviors of [Mrs. A] towards the fathers, has often led to conflictual relationship between these parties.”
3. What were the issues with the expert witness’ report?
In her ruling, Ms Justice Harris stated that the expert witness’ “conclusions and recommendations were fundamentally flawed by reason of her failure to proceed on the basis of the factual findings made by [the judge in the domestic abuse case]”.
Harris continued: “The fundamental difficulty is that contrary to the duties of an expert, Dr Parsi di Landrone did not consider the Court's findings within that broader framework of assessment but challenged the validity of the findings themselves. It is not a case of different professionals utilising different assessment tools, but a court appointed expert failing to proceed on the basis of the facts as determined by the Court in carrying out the risk assessment as instructed.”
Responding to di Landrone’s complaint that she was not given an opportunity to respond to concerns before a new psychologist was appointed, the judge said, “given the fundamental and pervasive nature of this failing, the Court is satisfied it was not susceptible to remedy through the raising of questions or points of clarification.”
She added, “The Court also has to note that Dr Parsi di Landrone's detailed response, continues to conflate the factual findings of the Court (which are not subject to question or challenge), with the process of assessing current risk.”
4. Why did the expert witness’ request for anonymity in the judgment fail?
Di Landrone requested anonymity in the judgment but was refused on the basis that her request did not meet the criteria, for example, to ensure the anonymisation of the child/family or to prevent a credible threat to an expert’s safety. Harris said there was a clear public interest in publishing the names of expert’s that have not met their duty to the court.
“The Court observes that experts have clear and important duties to the Court as set out within Part 25 of the Family Procedure Rules 2010. It is vital instructed experts understand those rules and comply with them. If they fail in those duties, it not only causes harmful delay and significant cost to the public purse, but undermines fair, sound and just decision-making by the courts,” she said.
“Whilst no doubt publication may be uncomfortable for Dr Parsi di Landrone and may impact on her professional standing, she has not been able to point to any matters that would engage her Article 8 rights in any significant way.”
Commenting on the fact that the expert had already been paid by the local authority and legal aid agency, the judge also said, “I am satisfied the fees of Dr Parsi di Landrone should not in principle be met from the public purse […]. I would invite her to consider whether she should out of good will return her fee to those public bodies.”
5. What can expert witnesses learn from this case?
While di Landrone’s evidence may not have materially altered the outcome of this case, which was to return the boy to his father’s care, it is a clear example of how important it is for experts to fully understand their duty to the court and to follow legal process.
This case has been heard against a changing landscape of increased scrutiny of family court experts. The government has recently closed a consultation on the standards required for psychologists as expert witnesses in family courts, after concerns were raised about the reliability of unregulated expert evidence, particularly in the context of accusations of “parental alienation”.
To stay up to date with the procedural framework in the family courts, consider enrolling on our two-day Family Law and Procedure – England and Wales course – the next date is the 23 October 2025. Delegates will understand how law is made and enforced; the court structure; the stages through which a case in court must pass and the different types of proceedings heard within the family courts. In response to recent criticism of expert witnesses operating the family courts, attendees will cover the rules relating to the expert witness including the sanctions that could be imposed.
To discuss this course or to place a booking, please contact expertwitness@bondsolon.com or
+44 (0) 20 7549 2549.