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England and Wales decisions
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A Council v JC & Ors [2025] EWFC 440 (11 December 2025)
Care proceedings concerning whether either parent caused fatal injuries to a toddler, alongside findings on delay, concealment, drug misuse, and L’s welfare.
Crawford (A Child), In the Matter Of [2025] EWFC 481 (B) (02 December 2025)
The Family Court made a final care order and placement order for a five-month-old child, finding the mother could not protect her from continuing domestic abuse risk.
The High Court dismissed a judicial review challenge to child protection plans made for two disabled children, holding the local authority acted lawfully and proportionately.
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 court found, on the balance of probabilities, that Z was brought to England on a false premise, her relationship with her mother was disrupted, she missed a year of formal education, and contact was severed without resolution. There is no reliable evidence that the mother sexually groomed Z or engaged her in sex work. The father and paternal family’s actions and inactions caused Z significant harm as defined by s.31 Children Act 1989.
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The threshold for care and placement orders is crossed due to sustained significant harm from domestic abuse, lack of boundaries, drug use, and inability of the mother to demonstrate or sustain change within the children's timescales. Removal from parental care and, for the younger children, adoption, are proportionate and necessary to safeguard their welfare. There are no realistic family alternatives, and continued parental care would perpetuate harm.
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The local authority failed to prove on the balance of probabilities that Child K's rib fracture was caused by a parent after birth. While birth-related rib fractures are rare and the medical evidence points against birth as the likely cause, the possibility of a birth injury could not be excluded given the research, expert evidence, and the absence of any risk factors or evidence of inflicted harm. Therefore, the threshold for significant harm attributable to parental care is not crossed.
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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.
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The London Borough of Hounslow v The Mother & Ors [2025] EWFC 341 (B) (13 October 2025)
Final care proceedings decision granting care orders for the eldest two children and placement orders for the youngest three after findings of domestic abuse and ongoing risk.
The fracture sustained by G was inflicted by the Father in the early hours of 9 March 2025 by application of significant and excessive force beyond reasonable handling, satisfying the threshold for care orders for G, K and S.
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