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England and Wales decisions
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Care proceedings fact-finding judgment finding neglect, excessive chores, and physical harm by F, but no finding that F viewed child abuse images or that M was sexually gratified.
North Lincolnshire Council v M1 & Ors [2025] EWFC 378 (B) (24 October 2025)
The Family Court found that F had subjected P to physical and emotional harm, some controlling and domestic abuse, and approved long-term foster care for P.
The threshold criteria under s.31(2) Children Act 1989 are satisfied because the father assaulted B by grabbing his neck with excessive force, causing physical harm and emotional harm to both children. The parents subjected the children to emotionally abusive language and behaviour, failed to provide stable housing, and minimised domestic abuse. The contemporaneous accounts of the children, corroborated by medical evidence and reliable witness testimony, outweigh the parents' denials and inconsistent explanations.
Source excerpt
The local authority failed to prove on the balance of probabilities that D sexually abused A due to significant inconsistencies in A's accounts, procedural failings in the investigation, and lack of corroborative evidence. However, threshold for a care order for A was established based on the mother's inability to care and D's admitted physical assault (flicking A in the face in anger).
Source excerpt
On balance of probabilities, F intentionally caused sexual harm to C by touching his penis, emotionally and psychologically abused C through repeated humiliating and inappropriate behaviour, exposed C to physical harm, and failed to provide safe parenting. C's allegations were consistent, credible, and corroborated by video evidence. Professional investigation was blighted by poor practice but did not undermine core findings.
Source excerpt
Cheshire West and Chester Council v C & Ors [2025] EWFC 434 (B) (02 October 2025)
Care proceedings concerning A and B. The court found threshold established for A, but not sexual abuse by D. A remains in residential care; B will transition back to D.
A Local Authority v M & Ors [2025] EWFC 302 (B) (08 August 2025)
The Family Court found threshold met in care proceedings concerning two children, accepting that the father caused physical harm and both parents caused emotional harm.
The court found, on balance of probabilities, that F subjected P and Q to physical and emotional harm, exposed them to inappropriate parenting, substance misuse, and controlling behaviour, but did not sexually abuse P. F's behaviour caused significant distress and harm to P. M1 exposed children to risk via substance misuse and unsafe contacts. M2 was subjected to domestic abuse and controlling behaviour by F. The threshold for care orders was met. P's welfare required placement in long-term foster care with indirect contact only.
Source excerpt
The threshold for intervention under s.31(2) Children Act 1989 is met: both children have suffered and are at risk of significant harm due to parental failures in health management, emotional availability, and neglect. Despite extensive support, neither parent can provide good enough care, and no lesser order would suffice. Removal to foster care is necessary and proportionate to safeguard the children's welfare, outweighing their wishes to remain with their mother.
Source excerpt
O & Y, Re (Parents with Learning Disability: Intermediaries) [2024] EWFC 7 (B) (26 January 2024)
Family Court care proceedings concerning two children and parents with learning disabilities. Care orders were made, with long-term foster care in separate placements.
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