D v London Borough of Bromley and Ors (Special Restrictions – Refusal of Adoption Order)

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

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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

  1. 1 Whether s.83(1)(a) of the Adoption and Children Act 2002 is engaged
  2. 2 Whether public policy requires refusal of the adoption order
  3. 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