C & Ors (ACA s51A: contact order after adoption), Re

C & Ors (ACA s51A: contact order after adoption), Re

A s51A contact order is necessary, proportionate, and better for the children's welfare than no order, due to the local authority's failure to support sibling contact, the need to safeguard sibling relationships, and to provide adopters with leverage for support, despite their agreement to contact.

Parties
Adoptive Parent of C and D: A1; Adoptive Parent of C and D: A2; Adoptive Parent of E and F: A3; Adoptive Parent of E and F: A4; Local Authority: London Borough of Waltham Forest; Birth Mother: BM; Birth Father: BF; Child: C; Child: D; Child: E; Child: F
Jurisdiction
England and Wales
Judgment Date
12 September 2025
Procedural Posture
Adoption Proceedings / Final Judgment on S51 a Contact Order Applications
Outcome
s51A contact order granted
Legal Topics
Adoption, Post Adoption Contact, Sibling Contact, Welfare Principle, No Order Principle
Family Law Child Law Adoption Post Adoption Contact Sibling Contact Welfare Principle No Order Principle

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Parties

A1

Adoptive Parent of C and D

A2

Adoptive Parent of C and D

A3

Adoptive Parent of E and F

A4

Adoptive Parent of E and F

London Borough of Waltham Forest

Local Authority

BM

Birth Mother

BF

Birth Father

C

Child

D

Child

E

Child

F

Child

Procedural Posture

Adoption Proceedings / Final Judgment on S51 a Contact Order Applications

Legal Issues

  1. 1 Should the court make a s51A order requiring adoptive parents to facilitate direct sibling contact post-adoption?
  2. 2 Is a s51A order necessary and proportionate given the adopters' agreement and the local authority's failures?
  3. 3 Does the welfare of the children require a contact order despite the 'no order' principle?

Ratio Decidendi

A s51A contact order is necessary, proportionate, and better for the children's welfare than no order, due to the local authority's failure to support sibling contact, the need to safeguard sibling relationships, and to provide adopters with leverage for support, despite their agreement to contact.

Court Disposition

s51A contact order granted

Orders

  • Each set of adoptive parents is required to make the children available for direct sibling contact at least twice a year.
  • Local authority is expected to support adopters in facilitating sibling contact.