Bristol City Council v B & Ors

Bristol City Council v B & Ors

The court found that, although the local authority did not prove the specific allegations of sexual abuse against Z, the evidence established that the father has a sexual interest in young girls, as demonstrated by his possession of indecent images and his sexual relationship with a child. The mother is emotionally dependent on the father, vulnerable to his influence, and unable or unwilling to recognise or act upon the risk he poses to D. Therefore, at the relevant date, D had suffered and was likely to suffer significant harm attributable to the care given or likely to be given by her parents, meeting the threshold for intervention under section 31 Children Act 1989.

Parties
Applicant: Bristol City Council; First Respondent (mother): B; Second Respondent (father): C; Third Respondent (child): D
Jurisdiction
England and Wales
Judgment Date
05 July 2025
Procedural Posture
Care and Supervision Proceedings / Fact Finding Hearing
Outcome
Threshold for significant harm under section 31 Children Act 1989 met; findings made as set out in the schedule.
Legal Topics
Care Proceedings, Sexual Risk Assessment, Significant Harm, Threshold Criteria, Parental Responsibility, Vulnerability and Exploitation, Admissibility of Evidence
Family Law Child Protection Care Proceedings Sexual Risk Assessment Significant Harm Threshold Criteria Parental Responsibility Vulnerability and Exploitation +1 more

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Parties

Bristol City Council

Applicant

B

First Respondent (mother)

C

Second Respondent (father)

D

Third Respondent (child)

Procedural Posture

Care and Supervision Proceedings / Fact Finding Hearing

Legal Issues

  1. 1 Whether the father poses a sexual risk to the child D
  2. 2 Whether the mother is able or willing to protect D from risk
  3. 3 Whether threshold criteria under section 31 Children Act 1989 are met

Ratio Decidendi

The court found that, although the local authority did not prove the specific allegations of sexual abuse against Z, the evidence established that the father has a sexual interest in young girls, as demonstrated by his possession of indecent images and his sexual relationship with a child. The mother is emotionally dependent on the father, vulnerable to his influence, and unable or unwilling to recognise or act upon the risk he poses to D. Therefore, at the relevant date, D had suffered and was likely to suffer significant harm attributable to the care given or likely to be given by her parents, meeting the threshold for intervention under section 31 Children Act 1989.

Court Disposition

Threshold for significant harm under section 31 Children Act 1989 met; findings made as set out in the schedule.

Orders

  • Findings of fact as per the schedule attached to the judgment.
  • Permission to publish anonymised judgment subject to strict preservation of anonymity.