City of Doncaster Council v The Mother & Anor
[2023] EWFC 324 (B)
B (A Child), Re, Disengaged mother
11 November 2024
[2024] EWFC 325 (B)
Family Court
A baby girl's mom had serious problems like drug use and mental health issues. The court decided the baby couldn't safely live with her mom, so it ordered the baby to be adopted to give her a safe and loving home.
Key Facts
- •B, a 1.5-year-old girl, is the subject of care and placement proceedings.
- •B's mother has a history of substance abuse, mental health issues (PTSD and EUPD), domestic abuse, criminality, and homelessness.
- •B's father is unknown.
- •B's mother's two older children were removed at birth and adopted.
- •B was initially placed in a mother and baby unit, but the placement broke down due to the mother's instability and concerning behavior.
- •B's mother disengaged from the proceedings and did not participate in court.
- •The local authority and guardian supported adoption as the only viable option for B.
Legal Principles
Paramountcy of the child's welfare.
Children Act 1989 and Adoption and Children Act 2002
Adoption should be a last resort; family ties should only be severed in exceptional circumstances.
Re B [2013] UKSC 33, YC v United Kingdom [2012] 55 EHRR 967
The court must consider all options and carry out a balancing exercise.
Re G [2013] EWCA Civ 965
Threshold criteria must be met for a public law order; the local authority must prove the child is likely to suffer significant harm.
Children Act 1989
For a placement order, the court must be satisfied that the parent's consent should be dispensed with.
Adoption and Children Act 2002
Outcomes
Care order made.
The court found the threshold criteria were met, and the mother's inability to provide safe care for B.
Placement order made.
The court dispensed with parental consent as it was in B's best interests to be adopted.