D (Threshold Findings and Final Orders at IRH), Re

The judge failed to make sufficient threshold findings and provide adequate reasons for the care and placement orders; reliance on procedural default and parental absence was improper; the orders must be set aside as the jurisdictional requirement for making them was not met.

Parties: First Appellant: Father; Second Appellant: Mother; First Respondent: Local Authority; Second Respondent: Child (D)
Jurisdiction: England and Wales
Judgment Date: 30 October 2025
Procedural Posture: Appeal (family Law Care and Placement Orders) / Judgment on Appeal From Final Orders at IRH
Outcome: Appeal allowed; care and placement orders set aside; interim care order substituted; applications remitted for urgent case management.
Legal Topics: Care Orders, Placement Orders, Threshold Criteria, Judicial Reasoning, Case Management, Burden of Proof

Family Law Child Protection Public Law Care Orders Placement Orders Threshold Criteria Judicial Reasoning Case Management +1 more

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Parties

Father

First Appellant

Mother

Second Appellant

Local Authority

First Respondent

Child (D)

Second Respondent

Procedural Posture

Appeal (family Law Care and Placement Orders) / Judgment on Appeal From Final Orders at IRH

Legal Issues

1 Whether the judge made sufficient threshold findings under section 31 Children Act 1989
2 Whether the judicial reasons for the care and placement orders were adequate

Ratio Decidendi

Court Disposition

Appeal allowed; care and placement orders set aside; interim care order substituted; applications remitted for urgent case management.

Orders

Discharge of care order and placement order made on 2 June 2025
Substitution of interim care order for D