S Dos Santos v Ofsted

S Dos Santos v Ofsted

Mrs Dos Santos failed to demonstrate understanding of safeguarding risks, failed to communicate honestly with Ofsted, unlawfully provided childcare while disqualified, and lacked sufficient safeguarding knowledge. Ofsted's refusal to grant a waiver was necessary and proportionate.

Parties
Appellant: Mrs S Dos Santos; Respondent: OFSTED
Jurisdiction
England and Wales
Judgment Date
17 December 2025
Procedural Posture
Appeal / Final Judgment
Outcome
appeal dismissed
Legal Topics
Disqualification by Association, Waiver of Disqualification, Safeguarding, Regulatory Compliance
Childcare Regulation Administrative Law Disqualification by Association Waiver of Disqualification Safeguarding Regulatory Compliance

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Parties

Mrs S Dos Santos

Appellant

OFSTED

Respondent

Procedural Posture

Appeal / Final Judgment

Legal Issues

  1. 1 Whether Mrs Dos Santos demonstrated understanding of the risk posed by her husband's offending and mitigation measures
  2. 2 Whether Mrs Dos Santos communicated honestly and openly with Ofsted
  3. 3 Whether Mrs Dos Santos unlawfully provided childcare while disqualified

Ratio Decidendi

Mrs Dos Santos failed to demonstrate understanding of safeguarding risks, failed to communicate honestly with Ofsted, unlawfully provided childcare while disqualified, and lacked sufficient safeguarding knowledge. Ofsted's refusal to grant a waiver was necessary and proportionate.

Court Disposition

appeal dismissed

Orders

  • The appeal is dismissed
  • Ofsted's decision dated 24 April 2025 to refuse waiver is confirmed