... concept of implacable hostility. A contact order requires the person with whom the child lives or is to live to allow the child to visit or stay with the person named in the order or that person and the child otherwise to have contact with each other1. There has been a strong presumption since the introduction of the Children Act and the implementation of section 8 orders that contact with an absent parent is generally in the best interests of the child. The courts have maintained this presumption over the last ten years. In Re R (A Minor) (Contact)2 LJ Butler Sloss provided that, "It is the right of a child to have a relationship with both parents wherever possible...when parents divorce the parent with whom the child does not live has a continuing role to play" This approach effectively requires the parent with the residence order to demonstrate to the court ...

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