F (A Child), Re (Care And Placement Orders) [2025] EWFC 309 (B) (29 July 2025)

F (A Child), Re (Care And Placement Orders) [2025] EWFC 309 (B) (29 July 2025)

The court found that the threshold criteria under section 31(2) Children Act 1989 were met: the parents are unable to provide safe, consistent, and adequate care for Faith, as evidenced by repeated failures with older siblings, lack of insight, minimal support network, and ongoing risks in the home. The welfare analysis concluded that Faith's welfare throughout her life requires adoption, as no other realistic option would sufficiently protect her from significant harm. Dispensing with parental consent is necessary and proportionate; nothing else will do.

Citation
[2025] EWFC 309 (B)
Parties
Applicant: Local Authority; First Respondent: Sophie (Mother); Second Respondent: Will (Father); Children's Guardian: Children's Guardian (Ms Muldowney)
Jurisdiction
England and Wales
Judgment Date
29 July 2025
Procedural Posture
Care and Placement Orders (family Law) / Final Judgment After Contested Hearing
Outcome
Care and placement orders made; parental consent to adoption dispensed with.
Legal Topics
Care Orders, Placement Orders, Adoption, Threshold Criteria, Welfare Principle, Parental Responsibility, Proportionality, Article 8 ECHR
Family Law Child Protection Adoption Care Orders Placement Orders Threshold Criteria Welfare Principle Parental Responsibility +2 more

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Parties

Local Authority

Applicant

Sophie (Mother)

First Respondent

Will (Father)

Second Respondent

Children's Guardian (Ms Muldowney)

Children's Guardian

Procedural Posture

Care and Placement Orders (family Law) / Final Judgment After Contested Hearing

Legal Issues

  1. 1 Whether the threshold criteria under section 31(2) Children Act 1989 are met for Faith
  2. 2 Whether Faith's welfare requires making care and placement orders for adoption, dispensing with parental consent

Ratio Decidendi

The court found that the threshold criteria under section 31(2) Children Act 1989 were met: the parents are unable to provide safe, consistent, and adequate care for Faith, as evidenced by repeated failures with older siblings, lack of insight, minimal support network, and ongoing risks in the home. The welfare analysis concluded that Faith's welfare throughout her life requires adoption, as no other realistic option would sufficiently protect her from significant harm. Dispensing with parental consent is necessary and proportionate; nothing else will do.

Court Disposition

Care and placement orders made; parental consent to adoption dispensed with.

Orders

  • Care order in respect of Faith
  • Placement order authorising placement for adoption