The Domestic Abuse bill of 2020 will massively impact people with multiple complex needs, the below includes our response and thoughts on the subject.
Response to the third reading of the Domestic Abuse Bill
In June 2020, the South East Fulfilling Lives team responded to the call for evidence by the government on the draft Domestic Abuse Bill 2020[1]. In response to the third reading of the Bill that was passed in the House of Commons on 6 July 2020, we are disappointed that there is little in the Bill that directly references women with multiple complex needs.
Why do women with multiple complex needs deserve focus and legal protections?
More than half of every one in 20 women who experienced extensive physical and sexual violence and abuse across their life course have a common mental health condition, one in five have experienced homelessness, and one in three have an alcohol problem[2]. In December 2018, 93% of the women on South East Fulfilling Lives’ own caseload had experienced domestic abuse. Of these women, 76% were homeless (rough sleeping/in temporary accommodation/sofa surfing/in hostels), 96% had both substance misuse and mental health needs when we began working with them, 88% had histories of offending, and 72% had disabilities.[3]
Why should the complex needs of domestic abuse victims be named and defined?
Domestic abuse takes place in a wider context and not all women experience similar levels of domestic abuse nor possess similar privileges or resources to get the right support at the right time. Women facing multiple disadvantage are some of the most marginalised victims of domestic abuse and an unequal society, and are often ostracized from society and support services. They are more likely to present with a history of extensive violence and abuse, have complex and overlapping needs such as high rates of mental health problems, substance misuse, contact with the criminal justice system and homelessness. They are also more prone to victim-blaming by professionals in statutory services or being labelled non-engaging or non-compliant by essential services[4].
Having a one-size-fits-all response to domestic abuse that fails to acknowledge different levels of vulnerability creates a culture around “worthy” and “unworthy” victims of domestic abuse. Therefore, we believe that the complexities of some of the most vulnerable victims’ lives should be named and adequately defined in order to provide more targeted support as well as legal protections. Whilst we welcome the widening of the statutory definition of domestic abuse to include emotional, coercive or controlling, and economic abuse, we also reiterate our call for the Bill to include a clear definition of ‘Multiple Complex Needs’.
Reconsidering New Clause 23: Commissioning specialist domestic abuse services
We are disappointed that a majority of MPs voted against the new Clause 23 which seeks to establish a statutory duty on relevant public authorities to commission specialist support and services to all persons affected by domestic abuse[5]. Women with multiple complex needs, who use the independent and women-led specialist domestic abuse services seldom respond well to traditional forms of service delivery models and access routes to support.
Our own project learning revealed that women with multiple complex needs are harder to reach, less visible to services and under-represented in statistics[6]. Research carried out by AVA and Agenda found that out of 173 local areas in England and Wales, only 19 had access to support for women facing multiple disadvantage that could address all of the following issues: substance use, criminal justice contact, mental-ill health and homelessness.[7] Survivors with complex needs and their children often require additional services and higher levels of support and outreach by trusted professionals who have the social skills and gendered understanding of how perpetrators operate and who can empathetically support them on their path to freedom and recovery.
In our experience, the response to domestic abuse continues to be siloed, with little joint work between the police, probation services, substance misuse services, children’s services and health practitioners and the specialist charities working supporting women. Victims of domestic abuse with complex needs require a holistic, comprehensive and whole-systems approach to tackling domestic abuse which includes partners in housing, health, relevant public authorities and statutory services in addition to the Bill’s sole focus on criminal justice and crisis response. This means an integrated cross-government response, rather than individual departments publishing separate guidance and being provided with separate funding arrangements.
Furthermore, those experiencing domestic abuse and complex needs may access a range of public services, such as their GPs, who are often the first point of contact.These non-specialist services play a crucial role in early intervention by identifying complex needs and recognising signs of abuse. Yet, women frequently do not receive a service which reflects an understanding of the complexities, dynamics and risk issues of domestic abuse or receive a trauma informed response, due to a lack of understanding. Thus, we urge for specific training duties for non-specialist domestic abuse services to be established in the Bill and embedded within the implementation plans. This echoes Agenda’s #AskAndTakeAction campaign, which places a duty on public authorities to ensure all frontline staff make trained enquiries into domestic abuse, which is crucial to ensuring victims get the support they need at the earliest possible opportunity [8].
We also hoped to see the Bill pave the way for new forms of accommodation that can provide emergency rapid-access accommodation that is self-contained and dispersed within communities, where wrap-around support is provided, and to include Specialist Multiple Complex Needs Refuge Accommodation as an option as often additional complex needs, such as substance misuse, excludes women from accessing the current refuge models, meaning many are being forced to return to their partner and abuser or being placed in non-specialist accommodation settings.
For the Domestic Abuse Bill to be truly transformational in its intent and also its outcomes, it is vital that no victim is left behind, and all victims feel heard, safe, and valued. Although many improvements have been made to the Bill, there are still holes in the protection the law provides to some of the most marginalised victims of domestic abuse. As the Bill is in the process of being scrutinised by the House of Lords[9], we hope further amendments will be tabled to ensure the scope of its protection is extended to all victims, especially those who have complex needs, and face multiple disadvantages and vulnerabilities simultaneously.
This post has been authored by Aditi Bhonagiri, with valuable contributions from Emily Page, Sandra Sylvester and Rebecca Riley.
If you have any questions after reading this piece, please feel free to get in touch with the author at aditi.bhonagiri@sefulfillinglives.org.uk
For more information on what we do, download our reports and resources please visit https://www.bht.org.uk/fulfilling-lives/
1 https://publications.parliament.uk/pa/cm5801/cmpublic/DomesticAbuse/memo/DAB86.pdf
2 http://weareagenda.org/wp-content/uploads/2015/11/Hidden-Hurt-full-report1.pdf
3 https://www.bht.org.uk/wp-content/uploads/2019/11/Fulfilling-Lives-Manifesto-for-Change.pdf
5 https://www.theyworkforyou.com/debates/?id=2020-07-06e.780.0#g781
6 Sarah Robinson, Oct 2016, Where are the Women?: Supporting Women with Multiple Needs. Cached at: https://wy-fi.org.uk/?mdocs-file=2277
7 https://avaproject.org.uk/resources/mapping-maze-full-report/
8 https://weareagenda.org/askandtakeaction/
9 https://services.parliament.uk/bills/2019-21/domesticabuse.html
Fulfilling Lives South East Partnership 
Aditi, very insightful article which highlights the need to invite inputs from organisations involved in helping or taking care of those for whom any legislation is brought in or amended.
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