COA:
371.
The complaint under this ground of appeal is that there was in existence material that might have been relevant to Sheila's attitude towards her children in the form of a letter to Nevill Bamber drafted by Sheila's former husband, Colin Caffell (but never sent), shortly after her release from hospital on the 29 March.
That letter expressed his concern about the effect that Sheila's mental condition was having on her ability to look after the two boys properly, to pay attention to their needs and requirements, to get them off to school in time and generally take care of them.
He was also concerned about the influence that Mrs Bamber had upon the two boys. In fact, it appears from the evidence that he gave at trial that he himself was caring for the two children for about 95% of the time.
He was seeking Nevill Bamber's support in convincing Sheila that the boys should continue to stay with him most of the time, and that he should have full control over their well-being. It is to be noted that he and Sheila had joint custody of the children.