M (A Child - Placement Order) [2014] EWCC B32 (Fam) (25 March 2014)

M (A Child - Placement Order) [2014] EWCC B32 (Fam) (25 March 2014)

The welfare of M requires a care order and placement order due to deficiencies in the mother's parenting ability and the need for a permanent, safe, and secure environment; the test for dispensing with parental consent is met as M's welfare necessitates it.

Citation
[2013] UKSC 33
Parties
Mother: JD; Father: CB; Applicant: Local Authority; Guardian: Children's Guardian
Jurisdiction
England and Wales
Judgment Date
02 October 2013
Procedural Posture
Care and Placement Order Proceedings / Final Judgment
Outcome
care order and placement order granted; parental consent dispensed with
Legal Topics
Care Order, Placement Order, Adoption, Parental Consent, Welfare Evaluation
Family Law Child Welfare Care Order Placement Order Adoption Parental Consent Welfare Evaluation

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Parties

JD

Mother

CB

Father

Local Authority

Applicant

Children's Guardian

Guardian

Procedural Posture

Care and Placement Order Proceedings / Final Judgment

Legal Issues

  1. 1 Whether a care order and placement order should be made for M
  2. 2 Whether parental consent should be dispensed with for placement order

Ratio Decidendi

The welfare of M requires a care order and placement order due to deficiencies in the mother's parenting ability and the need for a permanent, safe, and secure environment; the test for dispensing with parental consent is met as M's welfare necessitates it.

Court Disposition

care order and placement order granted; parental consent dispensed with

Orders

  • care order made
  • placement order made