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The Family Court made final care orders for A, B and C, and a placement order for C. Contact was reduced to support permanence and stability.
S, Re (Care and Placement: Schedule of Findings of Fact) [2026] EWCA Civ 85 (12 February 2026)
Court of Appeal partly allowed an aunt’s appeal in care proceedings, upholding a finding she likely brought Cytotec into the home but setting aside a finding she inserted misoprostol vaginally.
The Family Court granted a care order and placement order for EL, dispensed with the mother’s consent, and directed reconsideration of sibling and post-adoption contact.
The threshold criteria under section 31 Children Act 1989 are met as J suffered and was likely to suffer significant harm attributable to the mother's care, including abusive fractures and brain injury. The mother is unable to provide consistent, safe care and has not acknowledged responsibility. No other family member is suitable and the father is incarcerated. Adoption is necessary and proportionate as nothing else will do; J's welfare requires dispensing with parental consent for placement order.
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The threshold criteria under section 31(2) Children Act 1989 are met. U's welfare requires a care and placement order for adoption, with sibling contact order under section 26 Adoption and Children Act 2002. Parental consent is dispensed with as nothing else will do to secure U's welfare.
Source excerpt
The judge did not err in law or approach; she undertook a comparative welfare analysis, properly balanced the risks and benefits of adoption versus placement with the MGM, and was entitled to conclude that a placement order was neither necessary nor proportionate given the evidence. The appeal is dismissed.
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The appeal was dismissed because the judge was entitled to conclude that the plan to place M with the aunt and uncle was uncertain, involved unacceptable delay, and was not realistically achievable within M’s timescales. The judge properly applied the welfare checklists, balanced the competing factors, and found that adoption was necessary and proportionate to meet M’s welfare needs. Further delay for an uncertain outcome was contrary to M’s best interests.
Source excerpt
The Family Court found that a child was unlawfully removed from Nigeria using false documents and continued care and placement orders, refusing an Independent Social Worker.
The London Borough of Barnet v DL & Ors [2025] EWFC 168 (18 June 2025)
Family Court care and placement order proceedings concerning TT. The court held that adoption was the proportionate solution and made a care order and placement order.
London Borough of Tower Hamlets v UV & Anor [2025] EWFC 260 (B) (11 June 2025)
The Family Court made care and placement orders for AB, dispensed with the mother’s consent, and dismissed a kinship special guardianship application.
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