P (A Child), Re

P (A Child), Re

As of January 2015, the mother had not demonstrated a sufficient and sustainable change in circumstances to warrant permission to oppose the adoption order, and even if such change were established, the welfare evaluation would not justify disrupting the child's settled placement with the prospective adopter.

Parties
Appellant: Mother; 1st Respondent: Manchester City Council; 2nd Respondent: Children's Guardian
Jurisdiction
England and Wales
Judgment Date
22 July 2015
Procedural Posture
Appeal / Judgment on Appeal From Refusal of Permission to Oppose Adoption Order
Outcome
Appeal dismissed
Legal Topics
Adoption, Leave to Oppose Adoption Order, Change of Circumstances, Child Welfare, Attachment and Status Quo
Family Law Child Law Adoption Leave to Oppose Adoption Order Change of Circumstances Child Welfare Attachment and Status Quo

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Parties

Mother

Appellant

Manchester City Council

1st Respondent

Children's Guardian

2nd Respondent

Procedural Posture

Appeal / Judgment on Appeal From Refusal of Permission to Oppose Adoption Order

Legal Issues

  1. 1 Whether the judge erred in concluding that the mother had not shown sufficient change in circumstances since the placement order to satisfy s47(7) Adoption and Children Act 2002
  2. 2 Whether the mother should have been granted permission to oppose the making of an adoption order for her child

Ratio Decidendi

As of January 2015, the mother had not demonstrated a sufficient and sustainable change in circumstances to warrant permission to oppose the adoption order, and even if such change were established, the welfare evaluation would not justify disrupting the child's settled placement with the prospective adopter.

Court Disposition

Appeal dismissed

Orders

  • Mother refused permission to oppose the adoption order
  • Adoption order for child F may proceed