D v London Borough of Bromley and Ors (Special Restrictions – Refusal of Adoption Order)
The applicant brought the child into the United Kingdom for the purposes of adoption within the meaning of s.83(1)(a) of the Adoption and Children Act 2002. Special restrictions under s.9 of the Children and Adoption Act 2006 apply. The evidence demonstrates unreliable documentation, unresolved safeguarding concerns, risk of harm, and equivocal commitment by the applicant. Public policy and welfare both require refusal of the adoption order.
- Parties
- Applicant: DD; First Respondent: AF; Second Respondent: London Borough of Bromley; Third Respondent: FD (by her Children’s Guardian); Intervener: The Secretary of State for Education
- Jurisdiction
- England and Wales
- Judgment Date
- 25 February 2026
- Procedural Posture
- Adoption Application / Final Judgment
- Outcome
- Application for adoption order dismissed
- Legal Topics
- Cross Border Adoption, Special Restrictions on Adoptions From Abroad, Child Welfare, Public Policy, Recognition of Foreign Adoption, Immigration Consequences
Case Brief
Summary, issues, holding and outcome
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Parties
DD
Applicant
AF
First Respondent
London Borough of Bromley
Second Respondent
FD (by her Children’s Guardian)
Third Respondent
The Secretary of State for Education
Intervener
Procedural Posture
Adoption Application / Final Judgment
Legal Issues
- 1 Whether s.83(1)(a) of the Adoption and Children Act 2002 is engaged
- 2 Whether public policy requires refusal of the adoption order
- 3 Whether the welfare of the child throughout her life supports granting the adoption order
Ratio Decidendi
The applicant brought the child into the United Kingdom for the purposes of adoption within the meaning of s.83(1)(a) of the Adoption and Children Act 2002. Special restrictions under s.9 of the Children and Adoption Act 2006 apply. The evidence demonstrates unreliable documentation, unresolved safeguarding concerns, risk of harm, and equivocal commitment by the applicant. Public policy and welfare both require refusal of the adoption order.
Court Disposition
Application for adoption order dismissed
Orders
- No order as to costs
- Judgment to be provided to Chief Executive of Cafcass for review of Children’s Guardian approach
Full Case Text
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