There is some positive news, however.
In 2015, the Court of Appeal in England and Wales considered the case of Re P  EWCA Civ 170 in which the father was diagnosed by a forensic physiatrist as suffering from an ‘histrionic personality disorder and narcissistic personality disorder’. The report summarised the father’s behaviour as follows:
- He reacts to criticism (real or perceived) with feelings of rage;
- He is interpersonally exploitive taking advantage of others to achieve his own ends;
- He has a grandiose sense of self importance, e.g. exaggerating his achievement or talents;
- He expects to be noticed as “special” even without appropriate achievements;
- The corollary of this is his denegation of others without relevant cause;
- He believes his problems are unique and can only be understood by other special people;
- He is preoccupied with fantasies of unlimited success, power, brilliance, beauty or ideal love;
- He has a sense of entitlement and unreasonable expectation of especially favourable treatment; and
- He has a lack of empathy, inability to recognise and experience how others feel.
The result was a finding by an earlier court that the child P is likely to ‘suffer significant emotional harm arising from the adverse impact of the father’s mental health difficulties’. In part directly but also because of the impact of those difficulties on the relationship between the parents.
In addition, the judge also accepted the forensic psychologist’s view that, ‘as a result of his personality disorder the father was unable to identify P’s needs as distinct from his own which combined with the father being unable to have his opinion challenged and his need to control those around him’ rendered P vulnerable to harm.
In Re F (children, contact, name, parental responsibility)  EWFC 42, the judge found that making orders at ‘the most extreme end of the spectrum of Children Act Orders’ was both proportionate and necessary when severely restricting the father’s role in his children’s lives. An extract from the judgement explains:
‘The father has recently taken to referring to the mother as a drug-addicted alcoholic surrogate who has suffered from sexually transmitted diseases. This is the terminology of his blog and it is the terminology in which he has communicated with the welfare agencies. One example is the father’s provision to all 723 providers of nursery education in the mother’s county of his insulting analysis of the mother’s position…when questioned about this terminology, the father asserts that it is true but this is clearly contradicted by other evidence available to me in the case. He then says that the mother has insulted him by quoting his psychological assessment of narcissism, so, if she is insulting him, he is going to insult her. Finally, he says that he did not approve of the mother’s approach to the choice of nursery so, by spreading information about the mother to all local nursery providers, he was attempting to stop her acting contrary to his wishes.’
In October 2017, the the President of the Family Division gave directions to all judges deciding cases concerning child arrangements where there are allegations of domestic abuse and harm.
The Direction could be read as a ‘blueprint’ for tackling parents with NPD.
Domestic abuse was defined as:
‘Any incident or pattern of incidents of controlling, coercive or threatening behaviour, violence or abuse between people over 16 who are or have been intimate partners or family members.’
Coercive behaviour was clarified to be:
‘An act or a pattern or acts of assaults, threats, humiliation and intimidation or other abuse that is used to harm, punish, or frighten the victim.’
Controlling behaviour goes further:
‘An act or a pattern of acts designed to make a person subordinate and/or dependant by isolating them from sources of support, exploiting their resources… depriving them of the means needed for independence, resistance and escape and regulating their everyday behaviour.’
The Direction sets out clear rules of engagement for Judges dealing with cases where such behaviour arises including at para 33(a) ‘whether it would be assisted by any social work, psychiatric, physiologic or other assessment… of any party’.
This leaves us with real hope that the English Courts (and lawyers), now armed with clear definitions, will engage more readily with the damage caused by the narcissist in a family setting.
This article was originally published by Kingsley Napley