X (Revocations of Testamentary Guardianship)

X (Revocations of Testamentary Guardianship)

The testamentary guardianship order does not offend Article 17 as it was made before Mr X became a prospective adoptive parent; consent given by Mr X and Ms W is valid under domestic law and the Hague Convention; no basis for revocation of the guardianship order.

Parties
Applicant: X; Respondent: W
Jurisdiction
England and Wales
Judgment Date
22 April 2020
Procedural Posture
Family / Judgment
Outcome
Application refused
Legal Topics
Revocation of Testamentary Guardianship, Hague Convention Adoption, Consent to Adoption, Entrustment Under Article 17

Case Brief

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Parties

X

Applicant

W

Respondent

Procedural Posture

Family / Judgment

  1. 1 Whether consent under Article 4 of the Hague Convention is invalidated when a guardian consents to his own adoption application
  2. 2 Whether the term 'entrusted to prospective adoptive parents' in Article 17 is affected by the guardian's status

Ratio Decidendi

The testamentary guardianship order does not offend Article 17 as it was made before Mr X became a prospective adoptive parent; consent given by Mr X and Ms W is valid under domestic law and the Hague Convention; no basis for revocation of the guardianship order.

Court Disposition

Application refused

Orders

  • The application to revoke the testamentary guardianship order made in favour of Mr X and Ms W in 2015 is refused.