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West Northamptonshire Council (acting via Northamptonshire Childrens Trust) v KA (Mother & Anor) (Intermediaries)

[2024] EWHC 79 (Fam)
A little girl's case dragged on for a long time because her deaf mother had trouble understanding court proceedings. The judge decided that a special helper (intermediary) who understands sign language was needed to help the mother understand everything so the case could finally finish. The judge also considered similar cases to make this decision.

Key Facts

  • Care and placement order application for 2.5-year-old X after 127 weeks of proceedings.
  • Mother (M) is profoundly deaf.
  • Proceedings delayed due to issues with BSL interpreters and intermediary appointments.
  • Multiple assessments conducted, including parenting assessments of both parents and cognitive assessment of M.
  • Final hearing adjourned due to the non-attendance of the intermediary.
  • Court considers whether to make a wasted costs order against the intermediary and whether a deaf intermediary is necessary for the entire hearing.

Legal Principles

Appointment of intermediaries in family court cases should follow principles similar to those in criminal cases, ensuring fair trial rights.

R v Thomas (Dean) [2020] EWCA Crim 117

Appointment of an intermediary for the whole trial should be exceptionally rare and not made on a 'just-in-case' basis.

R v Thomas (Dean) [2020] EWCA Crim 117

Judges must consider the individual's circumstances and the case's specifics when appointing an intermediary.

R v Thomas (Dean) [2020] EWCA Crim 117

Intermediaries should only be appointed for compelling reasons, not merely to improve the process.

R v Thomas (Dean) [2020] EWCA Crim 117; R v Cox [2012] EWCA Crim 549

Judges must consider alternative adaptations to ensure effective participation before appointing an intermediary.

R v Thomas (Dean) [2020] EWCA Crim 117

Expert recommendations for intermediaries are not determinative; the decision rests with the judge.

R v Thomas (Dean) [2020] EWCA Crim 117

It is unusual for a case to be adjourned due to lack of an intermediary if every effort to find one has been made.

R v Cox [2012] EWCA Crim 549

Advocates should adapt their communication to the needs of vulnerable parties, using simple language and short questions.

R v Lubemba [2014] EWCA Crim 2064

Outcomes

No wasted costs order made against the intermediary due to a tragic family incident.

The intermediary's non-attendance was justified by unforeseen and tragic circumstances.

Order for a deaf intermediary to continue throughout the hearing.

M's profound communication difficulties, including deafness and wider cognitive issues, necessitate a deaf intermediary to ensure effective participation and prevent further adjournments. The use of a hearing intermediary with a deaf person presents particular challenges with BSL interpretation.

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