SK (Perplexing Presentation/Fabricated or Induced illness : PP/FII) [2022] EWFC 144 (24 October 2022)

SK (Perplexing Presentation/Fabricated or Induced illness : PP/FII) [2022] EWFC 144 (24 October 2022)

The court found that while the mother’s actions at times reflected over-cautiousness and misunderstandings, the evidence did not establish on the balance of probabilities that she deliberately fabricated or induced illness in B or C or caused them significant harm as defined by s.31(2) Children Act 1989. The...

Source-derived case information.

Citation
[2022] EWFC 144
Parties
Applicant: Local Authority; First Respondent: Mother; Second Respondent: Father; Third and Fourth Respondents: Children (B and C) through their guardian
Jurisdiction
England and Wales
Judgment Date
24 October 2022
Procedural Posture
Public Law Children Proceedings / Fact Finding Judgment Following a Hearing
Outcome
Threshold not met; no care or supervision order made for B and C.
Legal Topics
Care Orders, Supervision Orders, Significant Harm, Fabricated or Induced Illness (fii), Perplexing Presentation (pp), Threshold Criteria, Children Act 1989 S.31
Family Law Child Protection Care Orders Supervision Orders Significant Harm Fabricated or Induced Illness (fii) Perplexing Presentation (pp) Threshold Criteria +1 more

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Summary, issues, holding and outcome

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Parties

Local Authority

Applicant

Mother

First Respondent

Father

Second Respondent

Children (B and C) through their guardian

Third and Fourth Respondents

Procedural Posture

Public Law Children Proceedings / Fact Finding Judgment Following a Hearing

Legal Issues

  1. 1 Whether the threshold criteria under s.31(2) Children Act 1989 are met for B and C
  2. 2 Whether the mother has caused or is likely to cause significant harm to B and C through fabricated or induced illness (FII) or perplexing presentation (PP)
  3. 3 Whether the children have suffered or are likely to suffer significant harm attributable to the care given by the mother

Ratio Decidendi

The court found that while the mother’s actions at times reflected over-cautiousness and misunderstandings, the evidence did not establish on the balance of probabilities that she deliberately fabricated or induced illness in B or C or caused them significant harm as defined by s.31(2) Children Act 1989. The threshold for making a care or supervision order was not met in respect of B and C.

Court Disposition

Threshold not met; no care or supervision order made for B and C.

Orders

  • No public law order made in respect of B and C.
  • Anonymity of the children and family members to be strictly preserved.