SL (A Child) (Adoption : Home In Jurisdiction)

SL (A Child) (Adoption : Home In Jurisdiction)

The court held that the requirements of section 13(2) and section 13(3)(b) of the Adoption Act 1976 are separate and independent; the applicant's 'home' for section 13(2) does not need to be in England or Wales, provided the local authority had sufficient opportunity to see the child in the home environment in England or Wales for section 13(3)(b).

Parties
Applicant: Ms H; Child: SL; Legal Guardian: Director of Social Welfare of Hong Kong
Jurisdiction
England and Wales
Judgment Date
28 May 2004
Procedural Posture
Adoption / Final Judgment
Outcome
Adoption order granted
Legal Topics
Adoption, Jurisdiction, Statutory Interpretation

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Parties

Ms H

Applicant

SL

Child

Director of Social Welfare of Hong Kong

Legal Guardian

Procedural Posture

Adoption / Final Judgment

  1. 1 Does the English court have jurisdiction to make an adoption order when the applicant relocates to Scotland after filing?
  2. 2 Are the requirements of section 13 of the Adoption Act 1976 satisfied when the applicant's home is outside England or Wales at the time of hearing?

Ratio Decidendi

The court held that the requirements of section 13(2) and section 13(3)(b) of the Adoption Act 1976 are separate and independent; the applicant's 'home' for section 13(2) does not need to be in England or Wales, provided the local authority had sufficient opportunity to see the child in the home environment in England or Wales for section 13(3)(b).

Court Disposition

Adoption order granted

Orders

  • Adoption order made in favour of Ms H for SL
  • Dispensation with parental agreement due to inability to locate parents