G (A Child : placement order) [2018] EWFC B77 (22 August 2018)

G (A Child : placement order) [2018] EWFC B77 (22 August 2018)

The court found that the threshold for making a care order and placement order was met due to the parents' inability to provide safe and adequate care, the father's ongoing alcohol misuse and domestic violence, the mother's learning disability and epilepsy, and the absence of alternative carers. Adoption was the only realistic option to meet G's welfare needs, and parental consent was dispensed with as required by law.

Citation
[2018] EWFC B77
Parties
Applicant: A Local Authority; First Respondent (mother): M; Second Respondent (father): F; Third Respondent (child): G (by her Guardian)
Jurisdiction
England and Wales
Judgment Date
22 August 2018
Procedural Posture
Care and Placement Order Proceedings / Final Hearing and Judgment
Outcome
Care order and placement order made; parental consent to adoption dispensed with.
Legal Topics
Care Orders, Placement Orders, Adoption, Parental Responsibility, Child Welfare, Domestic Violence, Alcohol Misuse, Learning Disability
Family Law Child Protection Care Orders Placement Orders Adoption Parental Responsibility Child Welfare Domestic Violence +2 more

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Parties

A Local Authority

Applicant

M

First Respondent (mother)

F

Second Respondent (father)

G (by her Guardian)

Third Respondent (child)

Procedural Posture

Care and Placement Order Proceedings / Final Hearing and Judgment

Legal Issues

  1. 1 Whether the threshold for making a care order and placement order is met
  2. 2 Whether G's welfare requires adoption as the only realistic option
  3. 3 Whether parental consent to adoption should be dispensed with

Ratio Decidendi

The court found that the threshold for making a care order and placement order was met due to the parents' inability to provide safe and adequate care, the father's ongoing alcohol misuse and domestic violence, the mother's learning disability and epilepsy, and the absence of alternative carers. Adoption was the only realistic option to meet G's welfare needs, and parental consent was dispensed with as required by law.

Court Disposition

Care order and placement order made; parental consent to adoption dispensed with.

Orders

  • Care order in respect of G
  • Placement order authorising the local authority to place G for adoption