American child psychiatrist Richard Gardner (2002b, p.192), defines parental alienation syndrome (PAS) as “a disorder that arises primarily in the context of child-custody disputes. It's primary manifestation is the child's campaign of denigration against a good, loving parent, a campaign that has no justification. It results from the combination of a programming (brainwashing) parent's indoctrinations and the child's own contributions to the vilification of the target parent”. According to Gardner, women make up vast majority of parental programmers and indoctrinators. In short, Gardner claims that when children reject their fathers and when children or their mothers make abuse allegations in custody litigations, the behaviours are most likely the product of parental alienation syndrome rather than actual experiences of child (sexual) abuse.