England and Wales Case Law

London Borough of Havering v R & Ors

The court finds that threshold criteria are met due to the parents' vulnerabilities, substance misuse, lack of engagement, and inability to provide safe and consistent care for Q. Further residential assessment of R is not justified as it would cause delay, is unlikely to be positive, and is not in Q's welfare interests. There are no realistic family or friend placement options. Adoption is the only option that meets Q's immediate and long-term welfare needs. Parental consent to placement order is dispensed with as Q's welfare requires it.

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• Care orders
• Placement orders
• Parental responsibility
• Threshold criteria
• Welfare checklist
• Residential assessment

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B-A (Placement Order and Contact Order), Re

The Court of Appeal upheld a section 26 Adoption and Children Act 2002 order requiring annual face-to-face contact between two boys and their father after placement for adoption.

• Placement orders
• Contact orders
• Post-placement contact
• Adoption and children act 2002
• Children act 1989
• Sibling contact

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Cheshire East Borough Council v Mother & Ors

Adoption is necessary and proportionate for Child A as neither parent nor mother's friend D are realistic placement options; further delay is unjustified and contrary to Child A's welfare; the Placement Order application is procedurally valid and the court is satisfied that the threshold criteria are met.

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• Care orders
• Placement orders
• Adoption
• Delay in proceedings
• Kinship assessment
• Mental health

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N (A Child), Re

The court made final care and placement orders for a child aged nearly 3, rejecting further delay for a proposed family placement in India.

• Care orders
• Placement orders
• Special guardianship
• Adoption
• Delay in proceedings
• Welfare of the child

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A Council v The Mother & Ors

A Council v The Mother & Ors [2025] EWFC 419 (B) (02 December 2025)

Final care and placement orders were made for M after the court found adoption was the only realistic option. Parental consent to adoption was dispensed with.

• Care orders
• Placement orders
• Adoption
• Threshold criteria
• Parental responsibility
• Welfare of the child

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X, Re

The adoption order was made without proper notice to the birth father, constituting a procedural irregularity. The court, before sealing the order, must allow the father an opportunity to apply to set aside the order under Family Procedure Rules 27.5, as the error was identified promptly and the order not yet perfected.

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• Procedural irregularity
• Service of notice
• Setting aside adoption orders
• Appeal rights

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London Borough of Redbridge v Person C & Ors

Threshold criteria for care and placement orders are met; adoption is necessary and proportionate to secure permanence and stability for the children; family members are not ready or able to provide care meeting the children's needs; direct contact arrangements are endorsed but no s.26 order is made as Local Authority is committed to contact.

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• Care orders
• Placement orders
• Parental consent dispensation
• Contact arrangements
• Learning disabilities
• Domestic abuse

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R (Adoption of Foreign National Child), Re

Care and placement orders are refused because adoption is not necessary or proportionate; R's welfare, identity, and family ties outweigh the risks of family placement. M and MGM, with extended family and support from Brazilian services, can provide 'good enough' care for R. The LA failed to undertake a holistic analysis and dismissed family placement prematurely. Adoption would cause significant lifelong loss of identity and family, and there is no guarantee of a suitable adoptive placement. The risk of harm from F is mitigated by prohibiting contact and protective measures. R will return to…

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• Adoption of foreign national child
• Care orders
• Placement orders
• Parental responsibility
• Prohibited steps order
• Child welfare

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A Local Authority v X (Mother) & Anor

Given the fleeting nature of the relationship between X and Y's father, inability to identify the father, lack of realistic prospects for family placement, and the potential serious impact on X's mental health, the Local Authority is not required to take further steps to notify or identify Y's birth father or extended family before proceeding with adoption.

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• Adoption notification
• Parental responsibility
• Article 8 echr
• Confidential relinquishment
• Family placement alternatives

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London Borough of Camden v M & Ors

Care and placement order proceedings concerning a young child’s injuries, parental mental health, substance misuse, conflict, and family placement options.

• Care orders
• Placement orders
• Threshold criteria
• Parental mental health
• Substance misuse
• Domestic abuse

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