L-W Children [2019] EWCA Civ 159 (14 February 2019)

L-W Children [2019] EWCA Civ 159 (14 February 2019)

There was no evidence capable of supporting a finding that the mother failed to protect her children; GL's historic violence towards adults did not establish a causative link to risk of harm to children, and the mother's actions upon discovering injuries were appropriate.

Citation
[2019] EWCA Civ 159
Parties
Appellant: Mother; First Respondent: Carmarthenshire County Council; Second Respondent: PW; Third Respondent: GL; Fourth Respondent: LP
Jurisdiction
England and Wales
Judgment Date
14 February 2019
Procedural Posture
Appeal / Judgment on Appeal Against Finding of Failure to Protect
Outcome
Appeal allowed
Legal Topics
Failure to Protect, Threshold Criteria, Care Proceedings, Non Accidental Injury

Case Brief

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Parties

Mother

Appellant

Carmarthenshire County Council

First Respondent

PW

Second Respondent

GL

Third Respondent

LP

Fourth Respondent

Procedural Posture

Appeal / Judgment on Appeal Against Finding of Failure to Protect

  1. 1 Whether the mother failed to protect her children from risk of physical abuse by GL
  2. 2 Whether evidence supported a finding that the mother knew or ought to have known of risk

Ratio Decidendi

There was no evidence capable of supporting a finding that the mother failed to protect her children; GL's historic violence towards adults did not establish a causative link to risk of harm to children, and the mother's actions upon discovering injuries were appropriate.

Court Disposition

Appeal allowed

Orders

  • Finding of failure to protect against mother deleted
  • Care Proceedings in relation to W discontinued