Shared Residence: "The following year (February 1994) in the Court of Appeal, A v A (Minors: Shared Residence Order) underlined the prevailing view that shared residence orders were 'unusual' and were unlikely to be made if there were still unresolved issues between the parties, including the amount and nature of any contact.
Naturally, separating parents, particularly with a father seeking a shared residence order, probably with the mother opposing this and wanting a sole residence order in her favour, would have unresolved differences over contact.
Lady Justice Butler-Sloss said, 'It must be shown that there is positive benefit to the child concerned for a s 11(4) [an order specifying how the time was be allocated between the parents] order to be made.' Although it has been claimed that the requirements had been eased since the 'exceptional' had now become 'unusual', the door marked �Shared Residence Orders� was practically shut in fathers� faces by this judgement, made just two and a quarter years after the Children Act 1989 came into force."