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Local Authority 1 & Anor v Mother & Ors

[2024] EWFC 270 (B)
Two young siblings were taken into care because their mother used drugs and didn't care for them properly. Their father agreed that they should be adopted, and the judge decided that adoption was the best option to give them a safe and stable home for life, even though it means they won't live with their birth family.

Key Facts

  • Two children, QR (born 2020) and XR (born 2023), are subject to care proceedings.
  • Local Authority 1 applied for a placement order for QR on 21 March 2024.
  • Local Authority 2 applied for a care and placement order for XR on 11 June 2024.
  • The mother has not engaged with the proceedings and has not had contact with the children since December 2023.
  • The father supports the local authorities' applications for placement orders.
  • The mother has a history of social worker involvement due to concerns about drug misuse, domestic abuse, and neglect.
  • The mother tested positive for high levels of various drugs in January 2024.
  • Several family members were assessed but deemed unsuitable to provide a stable home.
  • The children have experienced multiple placement changes.

Legal Principles

Welfare of the children is the paramount consideration.

Children Act

No delay principle.

Not explicitly stated, but implied.

Guidance in Re P (Placement Orders: Parental Consent) [2008] EWCA Civ 535 regarding placement orders and parental consent.

Re P (Placement Orders: Parental Consent) [2008] EWCA Civ 535

Adoption and Children Act considerations regarding children's needs and the impact of adoption.

Adoption and Children Act

Outcomes

Care order for XR.

To ensure XR's welfare and safety.

Placement order for both children.

Determined that placement for adoption best meets the children's needs for stability and permanence due to the mother's inability to care for them and the lack of suitable alternative care options.

Dispensation with parental consent.

The mother's lack of engagement and the father's consent not being in the prescribed form. Even without consent, the judge would have dispensed with it due to the children's best interests.

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