London Borough of Waltham Forest v A & Anor [2023] EWFC 342 (B) (08 September 2025)

London Borough of Waltham Forest v A & Anor [2023] EWFC 342 (B) (08 September 2025)

The mother cannot safely or independently meet B's needs due to her mental health, lack of insight, cognitive limitations, and inability to implement professional advice despite extensive support. No realistic support package or family alternative exists. B's welfare requires a care and placement order with a plan for adoption, and the mother's consent to adoption is dispensed with as nothing else will do to secure B's welfare.

Citation
[2023] EWFC 342 (B)
Parties
Applicant Local Authority: London Borough of Waltham Forest; Respondent Mother: A; Child: B
Jurisdiction
England and Wales
Judgment Date
08 September 2025
Procedural Posture
Care and Placement Order Proceedings / Final Hearing
Outcome
Final care order and placement order made; mother's consent to adoption dispensed with.
Legal Topics
Care Orders, Placement Orders, Adoption, Parental Responsibility, Threshold Criteria, Welfare Checklist, Mental Health and Parenting, Dispensing With Parental Consent
Family Law Child Protection Care Orders Placement Orders Adoption Parental Responsibility Threshold Criteria Welfare Checklist +2 more

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Parties

London Borough of Waltham Forest

Applicant Local Authority

A

Respondent Mother

B

Child

Procedural Posture

Care and Placement Order Proceedings / Final Hearing

Legal Issues

  1. 1 Whether the threshold criteria under section 31 Children Act 1989 are met for a care order
  2. 2 Whether a placement order for adoption should be made and parental consent dispensed with
  3. 3 Whether the mother can safely and independently care for B

Ratio Decidendi

The mother cannot safely or independently meet B's needs due to her mental health, lack of insight, cognitive limitations, and inability to implement professional advice despite extensive support. No realistic support package or family alternative exists. B's welfare requires a care and placement order with a plan for adoption, and the mother's consent to adoption is dispensed with as nothing else will do to secure B's welfare.

Court Disposition

Final care order and placement order made; mother's consent to adoption dispensed with.

Orders

  • Final care order in favour of the Local Authority for B
  • Placement order authorising B's adoption