the body of case-law provides some minimal, visible protection against the outcome of an access dispute being dependent upon the length of a psychologist's or judge's foot. Whilst the circumstances of a particular child in a particular family must naturally dictate the ultimate solution in any access dispute, it is also important that both children and parents should be treated reasonably consistently throughout the country. For such reasons, the case-law on access has a value beyond the merely peripheral, and this brief article seeks to examine some of the trends which have emerged from judicial decisions, as reported until the end of 1989.