Birmingham City Council v CF & Ors
Threshold criteria are met due to longstanding parental vulnerabilities, criminality, substance misuse, and inability to safeguard the child. No realistic alternative carers exist. Adoption is necessary and proportionate to meet the child's immediate and lifelong welfare needs. Parental consent is dispensed with.
Source-derived case information.
- Parties
- Applicant: Birmingham City Council; Respondent: CF; Respondent: DS; Respondent: The Child (by their Children’s Guardian)
- Jurisdiction
- England and Wales
- Judgment Date
- 06 November 2025
- Procedural Posture
- Care and Placement Order Proceedings / Final Judgment
- Outcome
- final care order and placement order granted; parental consent dispensed with
- Legal Topics
- Care Orders, Placement Orders, Adoption, Parental Responsibility, Threshold Criteria, Mental Health, Substance Misuse, Domestic Abuse
Source-derived case record
Summary, issues, holding and outcome
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Parties
Birmingham City Council
Applicant
CF
Respondent
DS
Respondent
The Child (by their Children’s Guardian)
Respondent
Procedural Posture
Care and Placement Order Proceedings / Final Judgment
Legal Issues
- 1 Whether threshold criteria under s.31(2) Children Act 1989 are met
- 2 Whether care and placement orders are necessary and proportionate
- 3 Whether parental consent to adoption should be dispensed with
Ratio Decidendi
Threshold criteria are met due to longstanding parental vulnerabilities, criminality, substance misuse, and inability to safeguard the child. No realistic alternative carers exist. Adoption is necessary and proportionate to meet the child's immediate and lifelong welfare needs. Parental consent is dispensed with.
Court Disposition
final care order and placement order granted; parental consent dispensed with
Orders
- final care order made
- final placement order made
Full Case Text
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