FCC v WF & Ors [2016] EWFC B58 (18 July 2016)

FCC v WF & Ors [2016] EWFC B58 (18 July 2016)

There was no relevant change in the mother's circumstances since the Placement Order; her behaviour remained unstable with recent criminal convictions and no evidence of sustained improvement. There was no real prospect of success in revoking the Placement Order. The statutory test under section 24(3) was not met.

Citation
[2016] EWFC B58
Parties
Applicant: FCC; First Respondent (mother): MS; Second Respondent (father): WF; Children (by Their Guardian): RF and MF
Jurisdiction
England and Wales
Judgment Date
18 July 2016
Procedural Posture
Family Law Application to Revoke Placement Order / Judgment on Application for Permission to Revoke Placement Order
Outcome
Application dismissed
Legal Topics
Revocation of Placement Order, Change in Circumstances, Children's Welfare, Adoption Proceedings
Family Law Child Law Adoption Revocation of Placement Order Change in Circumstances Children's Welfare Adoption Proceedings

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Parties

FCC

Applicant

MS

First Respondent (mother)

WF

Second Respondent (father)

RF and MF

Children (by Their Guardian)

Procedural Posture

Family Law Application to Revoke Placement Order / Judgment on Application for Permission to Revoke Placement Order

Legal Issues

  1. 1 Whether there has been a change in circumstances since the Placement Order was made under section 24(3) Adoption and Children Act 2002
  2. 2 Whether the court should exercise its discretion to grant leave to apply for revocation of the Placement Order

Ratio Decidendi

There was no relevant change in the mother's circumstances since the Placement Order; her behaviour remained unstable with recent criminal convictions and no evidence of sustained improvement. There was no real prospect of success in revoking the Placement Order. The statutory test under section 24(3) was not met.

Court Disposition

Application dismissed

Orders

  • Mother's application for permission to revoke Placement Orders is dismissed.