X (Factitious Disorder)

X (Factitious Disorder)

The court found that the mother’s long-standing and recurrent mental health disorders, including factitious disorder and somatic symptom disorder, combined with a history of fabricated or induced illness towards her children, created a significant and ongoing risk of harm to X. Despite some progress, the mother’s inability to sustain change, lack of insight, and need for repeated basic care prompts rendered her unable to provide safe and stable parenting. Kinship care and residential assessment were not viable due to lack of suitable carers and the risk of further delay. Adoption was the only realistic and proportionate option to secure X’s welfare and permanence.

Parties
Applicant: The Local Authority; 1st Respondent: Mother; 2nd Respondent: Father; 3rd Respondent: X
Jurisdiction
England and Wales
Judgment Date
11 May 2021
Procedural Posture
Care and Placement Proceedings (public Law) / Final Judgment
Outcome
Care order and placement order for adoption granted; parental consent dispensed with; application for further kinship assessment refused.
Legal Topics
Care Orders, Placement Orders, Adoption, Parental Responsibility, Factitious Disorder, Somatic Symptom Disorder, Fabricated or Induced Illness (fii), Threshold Criteria, Welfare Principle, Kinship Assessment
Family Law Child Protection Care Orders Placement Orders Adoption Parental Responsibility Factitious Disorder Somatic Symptom Disorder +4 more

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Parties

The Local Authority

Applicant

Mother

1st Respondent

Father

2nd Respondent

X

3rd Respondent

Procedural Posture

Care and Placement Proceedings (public Law) / Final Judgment

Legal Issues

  1. 1 Whether the threshold criteria under s31 Children Act 1989 are met for X
  2. 2 Whether X should be placed for adoption outside the birth family
  3. 3 Whether the mother’s mental health and behavioural patterns pose a risk of significant harm to X

Ratio Decidendi

The court found that the mother’s long-standing and recurrent mental health disorders, including factitious disorder and somatic symptom disorder, combined with a history of fabricated or induced illness towards her children, created a significant and ongoing risk of harm to X. Despite some progress, the mother’s inability to sustain change, lack of insight, and need for repeated basic care prompts rendered her unable to provide safe and stable parenting. Kinship care and residential assessment were not viable due to lack of suitable carers and the risk of further delay. Adoption was the only realistic and proportionate option to secure X’s welfare and permanence.

Court Disposition

Care order and placement order for adoption granted; parental consent dispensed with; application for further kinship assessment refused.

Orders

  • Threshold findings made as outlined in the judgment
  • Care plan for adoption approved