E, F, G & H (Children), Re (Fostering or Adoption) [2025] EWFC 17 (B) (22 January 2025)

Source-derived case information.

Citation: [2025] EWFC 17 (B)
Parties: Applicant: BCP Council; 1st Respondent (mother): Ms M; 2nd Respondent (father of E, F, G): Mr A; 3rd Respondent (father of H): Mr B; 4th – 7th Respondents (by Their Children's Guardian): The Children (E, F, G, H)
Jurisdiction: England and Wales
Judgment Date: 22 January 2025
Procedural Posture: Care and Placement Proceedings (children Act 1989, Adoption and Children Act 2002) / Final Hearing and Judgment
Outcome: Care orders made for E, F, G, and H; placement order for adoption made for H; parental consent to placement order dispensed with.
Legal Topics: Care Orders, Placement Orders, Threshold Criteria, Domestic Abuse, Substance Misuse, Parental Capacity, Children's Welfare, Contact Arrangements

Family Law Child Protection Adoption Law Care Orders Placement Orders Threshold Criteria Domestic Abuse Substance Misuse +3 more

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Full judgment text Downloadable case file Legal principles 6 Authorities cited 16 Party arguments 2

Parties

BCP Council

Applicant

Ms M

1st Respondent (mother)

Mr A

2nd Respondent (father of E, F, G)

Mr B

3rd Respondent (father of H)

The Children (E, F, G, H)

4th – 7th Respondents (by Their Children's Guardian)

Procedural Posture

Care and Placement Proceedings (children Act 1989, Adoption and Children Act 2002) / Final Hearing and Judgment

Legal Issues

1 Whether threshold for care orders under s.31 Children Act 1989 is met for E, F, G, H
2 Whether a placement order for adoption should be made for H under Adoption and Children Act 2002
3 Whether the welfare of the children requires removal from parental care and long-term foster care or adoption

Ratio Decidendi

The threshold for care orders under s.31 Children Act 1989 is met for all four children due to significant harm from domestic abuse, substance misuse, and lack of consistent, safe parenting. The parents have not demonstrated sufficient insight or sustained change, and the risks cannot be managed safely within the family. Long-term foster care is the only realistic option for E, F, and G. For H, given her age and need for permanence, adoption is the only option that meets her welfare needs. Parental consent to placement order for H is dispensed with as her welfare requires it.

Court Disposition

Care orders made for E, F, G, and H; placement order for adoption made for H; parental consent to placement order dispensed with.

Orders

Final care orders for E, F, G, and H
Placement order for H authorising adoption

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