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England and Wales decisions
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B-A, Re (Placement Order and Contact Order) [2026] EWCA Civ 356 (25 March 2026)
The Court of Appeal upheld a section 26 ACA 2002 order for annual face-to-face contact between adopted children and their father, despite family-finding concerns.
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.
Caerphilly County Borough Council v M & Ors [2025] EWFC 200 (B) (04 July 2025)
The court made a care order for a young child after finding parental dishonesty, drug use, domestic conflict, and failures to follow safety planning.
The threshold for a care order under section 31 Children Act 1989 is met due to parental dishonesty, drug misuse, unsafe environment, and failure to comply with care plans. The only order capable of meeting A's welfare needs is a Care Order with A to remain in foster care. Monthly supervised contact is proportionate and unsupervised contact is not appropriate at this time. The Local Authority's failings did not materially influence parental conduct but emboldened their deception. It is not proportionate for the court to restrict the Local Authority's duty to promote contact.
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HM v HF [2024] EWFC 441 (B) (16 December 2024)
The Family Court ordered that two children live with their mother, with only indirect contact with their father, due to his mental health instability and risk of harm.
Disclosure of the fact-finding judgment to the Father's employer (MOD) is refused because comprehensive disclosure has already been made to the police, who are bound by statutory and common law safeguarding duties and protocols with the military; there is no evidence that the Father's employment brings him into contact with vulnerable persons, and further disclosure is unnecessary and disproportionate. The court is entitled to assume that regulatory and investigatory bodies follow law and procedure. No further psychiatric expert evidence is ordered as the Mother refuses assessment; the court…
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The High Court dismissed a father's appeal against an order allowing the mother to relocate to Alberta, holding the decision fell within the judge's discretion.
The threshold for making final care orders was met due to proven facts of lack of supervision, failure to seek medical attention, sexual and physical abuse, exposure to cannabis, inappropriate chastisement, and controlling behaviour by the father. The welfare of the children required placement in long-term foster care, refusal of father’s contact, and a section 91(14) order restricting father’s applications for four years to protect therapeutic support and prevent risk of harm.
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A local Authority v M & Ors [2024] EWFC 243 (B) (09 August 2024)
Care proceedings concerning four children with complex needs. The court made final care orders, approved the care plans, and left contact to the local authority.
The mother failed to prove on the balance of probabilities that the father caused emotional or physical harm to Child A in all but one allegation, which the father admitted and for which he showed remorse. The evidence was largely hearsay, contaminated by suggestibility and the mother’s conduct. The welfare of the children requires a resumption of contact with the father, initially supervised and progressing to unsupervised and overnight contact, as there are no safeguarding concerns justifying restriction.
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