DARVO and the English Family Courts: recognising and responding to manipulation

This month, in her report to parliament the Domestic Abuse Commissioner found that 87% of the case files it reviewed had evidence of abuse. It was also prevalent in 73% of the hearings it observed.

The report also confirmed that “the substantive outcomes of financial remedy proceedings are leaving survivors vulnerable…and perpetuate rather than address the consequences of economic abuse”…… “Two recent decisions of the High Court, Tsvetkov v Khayrova and N v J, contribute to these concerns.  These decisions erect substantial barriers to applicants wishing to argue that domestic abuse in the marriage amounts to “conduct”… they mirror in financial proceedings the practices found by the Harm Panel …whereby only exceptional instances of abuse… receive a response, resulting in many orders being made that expose adult and child victims of abuse to the risk of further abuse and material harm.”

When survivors of domestic abuse turn to the family courts for protection, for assistance with financial settlements or for decisions about their children, they often find themselves facing not only absolute denial, but also counter-attacks, even allegations that they are the aggressor. Increasingly, this pattern of behaviour is being recognised for what it is: DARVO.

What is DARVO?

The acronym DARVO — first coined by psychologist Jennifer Freyd — describes a manipulative response often used by perpetrators when confronted with their behaviour:

1. Deny – “That never happened” or “You’re making it up.”
2. Attack – Discrediting the accuser, questioning their sanity, or accusing them of ulterior motives.
3. Reverse Victim and Offender – Casting themselves as the “real” victim, while painting the abused party as controlling or abusive.

This sequence is not accidental. It is a strategic way of dodging accountability, shifting blame, and destabilising the person raising concerns.

DARVO in practice

Psychological research shows that when observers hear DARVO responses, they are more likely to view the accuser as untrustworthy and the alleged perpetrator as less culpable. In English family proceedings, this has particular significance: decisions about children and safety are often made on the “balance of probabilities,” and credibility is crucial.

Reports from survivors reveal consistent patterns:

1. Abusers denying non-physical forms of abuse, such as coercive control.
2. Aggressive cross-allegations.
3. Perpetrators seek to “weaponise” the court process by making false counterclaims, dragging out proceedings, and undermining credibility.
4. Reversal tactics, where the survivor of abuse is reframed as unstable, vindictive, or manipulative.

These mirror the DARVO framework precisely.

How DARVO links with gaslighting and coercive control

Gaslighting undermines a victim’s confidence in their own memory or perception — making DARVO denials more convincing. Coercive control, recognised as a criminal offence under the Serious Crime Act 2015, describes a broader pattern of intimidation and control. DARVO is often one of the tools within this pattern.

While DARVO itself is not a statutory term in English law, courts are increasingly hearing evidence of these manipulative behaviours within wider allegations of domestic abuse.

Evidence of DARVO in the Family Courts

Recent studies and official reviews provide strong evidence that DARVO-like tactics are at play in family proceedings.

The Domestic Abuse Commissioner’s 2023 report on family courts found survivors often felt disbelieved when their ex-partner denied abuse and counter-alleged that they were the controlling one. This “role reversal” left victims retraumatised and fighting to be heard.

In private law children cases, Cafcass has reported the increasing number of adults stating they are the victim of alienating behaviours in the family courts.

Together, these findings show DARVO is not a theoretical concept: it is operating, daily, in English family courts.

Why does it matter?

Understanding DARVO is critical for survivors, who may otherwise internalise blame or doubt their credibility. For lawyers and advisers, who must gather evidence of denial, attack and reversal as part of a broader pattern of coercive control and for Judges and Cafcass officers, who are tasked with distinguishing genuine concerns from manipulative counter-allegations.

Failure to spot DARVO risks miscarriages of justice: children placed in unsafe arrangements, survivors silenced, and abusers emboldened.

Practical steps for survivors and practitioners

If you believe DARVO tactics are being used against you in family proceedings:

1. Document everything – Keep detailed records of incidents, communications and attacks on your credibility.
2. Seek corroboration – Medical records, police reports, or witness statements can counter denials.
3. Anticipate counter-allegations – Prepare with your solicitor for the possibility of reversal tactics.
4. Frame it legally – Courts may not use the word DARVO, but describing behaviour as “false counter-allegations,” “credibility undermining,” or “pattern of coercive control” gives it legal resonance.
5. Look after yourself – DARVO is designed to destabilise. Support from friends, professionals and domestic abuse services is vital.

Looking ahead

The family courts in England and Wales are under increasing pressure to become more trauma-informed and to understand non-physical forms of abuse. Awareness of DARVO, alongside gaslighting and coercive control, is an important step in that cultural shift.

Recognising DARVO does not just help survivors — it helps the courts deliver justice, protect children, and prevent the legal system itself being manipulated as a tool of abuse.

If you would like advice on how DARVO and coercive control may affect your case, please contact Claire O’Flinn and Isobel Mundy.

If you or someone you know is in immediate danger, please contact the police.