Jersey Unreported Judgments

Care order - application by the Minister for a final care order and a freeing for adoption order.

[2016]JRC191

Royal Court

(Family)

19 October 2016

Before     :		J. A. Clyde-Smith, Esq., and Jurats Crill and Thomas
Between	The Minister for Health and Social Services		Applicant
And	A (the mother)		First Respondent
And	Charlie (the child, through her Guardian ad litem, Eleanor Green)		Second Respondent

IN THE MATTER OF THE CHILDREN (JERSEY) LAW 2002

AND IN THE MATTER OF CHARLIE (CARE ORDER AND FREEING FOR ADOPTION ORDER)

Advocate P. F. Byrne for the Minister.

Advocate C. Davies for the Second Respondent.

Advocate A. T. H. English appeared as amicus curiae.

judgment

the commissioner:

1.        On 27^th September, 2016, the Court granted the applicant ("the Minister") a final care order in respect of the second respondent ("the child"), who is aged 6 months, and freed her for adoption.  We now set out our reasons. 

2.        This was a troubling case in which the mother, who had the intellectual capacity to parent the child, had completely disengaged from the Children's Service and other agencies, the lawyer appointed to act for her and the Court process.  She did not attend the hearing; the Court resolving to continue in her absence pursuant to Rule 17(4) of the Children Rules 2005. 

3.        The mother was born and brought up in Thailand.  She left school at an early age and went to work in Bangkok, working ultimately in a bar there.  She described her work in this way, namely that customers would take her out to dinner or drinks or a night club and would ask her to stay with them.  She described some traumatic experiences whilst working in this way.  It was through this work that she met Mr B from Jersey.  She moved with him to Jersey and they were married.  

4.        The mother suffered a still birth in Thailand and another in Jersey, but she gave birth to two children with Mr B.  She left the family home in February 2013 to live in the Women's Refuge, following which private law proceedings were issued.  In those proceedings, she was assessed by Dr Carritt-Baker, a chartered clinical psychologist, but refused to undertake the psychological work he recommended.  She asked for a psychological assessment of the children in relation to their contact with her, but declined to cooperate with the psychologist appointed, Dr James Murray. 

5.        Dr Murray did interview the children, then aged 9 and 7.  The eldest child in particular painted a troubling picture of life with their mother, describing the mother as "hurting me a lot, kicking and punching, and using bad words."  She was scared of her mother and neither child wanted contact with the mother.  She described a particular incident when the mother had assaulted the paternal grandmother in public, to which the police were called.  The police reported that the children were visibly shaken, due to what they had witnessed. 

6.        The mother dispensed with the services of the lawyer appointed to represent her in these private law proceedings and on 31^st October, 2013, the Court ordered that the children reside with the father, with the mother only having indirect contact, as recommended by the Jersey Family Court Advisory Service.  She has not had any contact with these children since.  

7.        The Act of Court noted that the mother had not attended Court in support of her application or to collect the report of Dr Murray, despite being requested to do so.  The JFCAS officer had informed the Court that she had tried on several occasions to contact the mother, but she had been unable to communicate with the mother.  The JFCAS report explained that it was very difficult to engage with the mother.  She had been interviewed on two occasions with interpreters who struggled to understand some of her comments, describing some of the things she was saying as "bizarre". 

8.        The mother became pregnant with the child around the summer of 2015. 

9.        At around the same time, there was an incident at the Homeless Shelter, in which the mother was then residing and still now resides, when she assaulted another resident.  She pleaded guilty in the Magistrate's Court to grave and criminal assault and malicious damage and was sentenced to 70 hours' community service. 

10.      It was through the Probation Department, who noticed in December 2015 that she was heavily pregnant, that concerns were raised because she had not accessed medical care and seemed unaware of when the child was due.  This was of particular concern in the light of her problematic obstetric history, the risk of gestational diabetes (of which she had a history) and her intention of giving birth on her own. 

11.      The mother appeared to have no plans as to where she and the child would live (she could not have the child living with her at the Homeless Shelter) and had made no preparation for the arrival of the child. 

12.      While she did build some kind of working relationship with the health team at the hospital, she demonstrated a reluctance to work with the health care plan and accept the health professional's advice.  She failed to comply with dietary advice to ensure the child received essential nutrients and sought to stabilise her blood sugars without medication.  She was fully aware of her history of gestational diabetes and the importance of complying with advice.  She was given prescribed medication to manage this; however, she failed to take it as prescribed and could not stabilise her blood sugars through diet.  The mother was admitted to hospital because the gestational diabetes was not being managed. 

13.      The pre-birth assessment of 10^th February, 2016, highlighted extensive risks for the child and recommended removal at birth.  The mother had been reluctant to work with the Children's Service, refusing to name the father or members of her family.  She gave the Children's Service the impression of being dictated to by the un-named father, who she said had told her not to get medical help and not to tell anyone about the pregnancy.  She refused to sign the Legal Aid forms.  

14.      The child was born by Caesarean section on 8^th March, 2016. 

15.      On 14^th March, 2016, the Court granted an interim care order to the Minister, approving a care plan providing for the temporary removal of the child out of the jurisdiction with the mother for an assessment, for the reasons set out in the Court's judgment of 14th April 2016 (In the matter of Charlie (Care order) [2016] JRC082).  The mother was fully aware of the hearing, but did not attend.  Advocate English had been appointed on Legal Aid to represent her, but despite extensive efforts, was without instructions. 

16.      The plan was for the mother and child to attend a 12 week assessment at an assessment centre called St Michael's Fellowship in London.  She displayed a lack of enthusiasm for or engagement in that proposed assessment and the St Michael's Fellowship concluded that they could not work with her.  Furthermore, the mother had refused to sign the parish travel ID document, which would have enabled her and the child to travel to London, because she wanted a passport.  In the light of her stated wish to return to Thailand with the child, it was felt that should she travel to London with the child there was a real risk of her taking the child to Thailand.  The child was therefore placed in foster care, where she has remained ever since.  

17.      On 31^st March, 2016, Advocate English was appointed amicus curiae and on 4^th May, 2016, a further psychological report was commissioned from Dr Carritt-Baker.  The mother was directed to provide the Minister with names and contact details of any person who she wished to put forward as alternative carers for the child, which she has failed to do. 

18.      The mother's apparent ownership of a house in Thailand has presented a barrier to her being able to claim Income Support in Jersey.  The mother has only attended the Social Security Department once on 20^th April, 2016, with their records showing that most of the contact with the department has been by professionals, trying to support and enable the mother to receive Income Support.  She lives at the Homeless Shelter which funds her accommodation and provides her with meals, access to laundry and bathroom facilities.  She told the social worker, Diane Burgess, that she earns money through "being nice to men", "going out with them" in the capacity as an escort and doing "nice things" to men, which led Diane Burgess to believe that she was a sex worker. 

19.      In April 2016, Diane Burgess, approached the manager of the facility at Midvale Road so that an extended assessment of the mother could be undertaken there through contact.  Steps were taken to put the necessary funding in place.  The mother was uncooperative with this proposal, because she would be unable at Midvale Road to go out more than three nights a week, as she was doing at the Homeless Shelter, often returning at 6am. 

20.      At one stage, the mother did name a person as the putative father (who absolutely denied paternity) but subsequently confirmed that he was not the father.  The mother has talked about the father, but refused to name him.  Diane Burgess had tried to explore whether the mother and the child would be able to live with this man.  The mother made it clear it would be a really bad environment, as he always had some woman living in another room and swops partners very often. 

21.      Throughout this period, the mother has been attending contact sessions five days a week, and most of that went well in that, in the words of Dr Carritt-Baker, she achieved a reasonable bond in the circumstances and was attuned to the child, but contact had to be suspended on two occasions, as a consequence of her very aggressive and abusive response, in the presence of the child, to being given advice.  

22.      In July 2016, the mother refused to allow the child her immunisations, becoming angry and aggressive with the health visitor when she tried to explain their importance. 

23.      Diane Burgess consulted with the guardian Eleanor Green as to whether it would be sensible to make another offer to the mother of an off-Island placement.  A meeting took place on the 1^st August, 2016, with the mother, Eleanor Green and Diane Burgess, in the presence of an interpreter, and the mother was asked if she would be prepared to go to the St Michael's Fellowship in London with the child to have her parenting capacity assessed over a twelve-week period.  Despite the best efforts of the professionals, they could not convince her to agree to this.  She said that she would think about it and at a further meeting on 4^th August, 2016, she maintained her refusal, accepting that this might mean that the child would be adopted.  When the implications were explained to her, she became angry and aggressive.  Eleanor Green told us in evidence that there was no question that the mother understood what was being offered and the implications. 

24.      Dr Carritt-Baker found it difficult to engage the mother in an assessment process, both in terms of getting her to attend and in terms of meaningful involvement.  She talked in a tangential way, in which her answers often bore little relation to the questions put to her.  There was no evident reason to think that she was experiencing pronounced symptoms of a mental health problem, although the emphasis is on the word "pronounced", as there clearly were mental health issues which were not easy to pin down.  The most likely, and possibly only, characteristic is an anxiety disorder but she is also perhaps experiencing some depressive symptoms. 

25.      From his assessment in 2013 and this assessment, he had no reason to think that cognitive issues were very relevant to questions of her parenting capacity.  In general, from the cognitive or intellectual perspective, she should be able to provide parenting without support. In paragraphs 6.6 to 6.8 of his report, he said this about her failure to engage:-

"6.6     Whilst it is difficult to be sure why she has responded in the way she has to the current set of circumstances, the issues that did emerge were:

she experiences anxiety and jumbled thoughts when thinking about these issues

she reacts emotionally to attempts to engage her and then shuts down

she has very strong thoughts and feelings about her other children that interfere with her ability to engage with this process

6.7      The question that arises in such cases is whether these issues can constitute a barrier to having capacity.  There are perhaps a few things to consider here:-

A person is presumed to have capacity unless it can be demonstrated that they do not

Making what are considered to be 'unwise decisions' that are perhaps driven by emotional factors is not a reason to determine that there is lack of capacity

A failure to engage in a process is not, in itself, an indication of a lack of capacity: it is one of the choices that people who have capacity can make

In more extreme cases, where, say a person experiences outright dissociative episodes when engaging in the process, it might be possible to say that they lack capacity

6.8      The thorniest component of a test of capacity in such circumstances is perhaps whether she is able to use or weigh the relevant information.  This aspect of the test has been described as 'the capacity actually to engage in the decision-making process itself and to be able to see the various parts of the argument and to relate the one to another'.  The ability to understand also extends to understanding the reasonably foreseeable consequences of reaching a decision or failing to do so.  An ability to engage in any way in the process might constitute a lack of capacity on these grounds.  However, in Ms A's case, I think she has demonstrated that it is because of her strong feelings about the possible consequences that she finds it difficult to engage: I would tend to take this as an indication that she is making use of the relevant information even if in only a partial way."

26.      In his view the risks to the child stem from the mother's lifestyle and inability to engage appropriately with services who were trying to support her in making changes.  In the absence of sustained meaningful engagement, the risks were really quite difficult for him to quantify, and in his view the reasonable approach would be to assume that they are moderate at least.  If the mother had been able to engage in the wider assessment process with other professionals over a period of months, then it might have been possible to determine that she is able to provide good enough care. 

27.      He explained that when the mother experiences strong feelings, she either closes down or explodes out - hence the volatility at contact sessions, but the priority for her was to protect herself.  It was a reflexive reaction to avoid strong feelings or distress.  She could appreciate the child's best interests some of the time, but not enough of the time and to the necessary extent.  Even if she could be placed with the child in a house with money, it would be too risky.  Her conduct with her older children was very concerning, and in his view, she would be a risk to the child if left to her own devices. 

28.      He advised that there was no realistic prospect of the mother engaging in psychological treatment that might help to unpick the issues behind her sustained lack of engagement with the services that would realistically result in a sustained set of changes that would resolve the risks present. 

29.      Eleanor Green, despite her best efforts, was only able to achieve a very superficial engagement with the mother.  She did not feel that she understood the mother and only scratched the surface of the mother's problems.  The mother had a "scatter gun" way of expressing herself that was difficult to keep a track of.  It was impossible to have a logical conversation with her - Eleanor Green felt it was some form of disordered thinking.  She could be quite explosive in a way that was frightening to adults.  

30.      In her view, Diane Burgess had done everything possible to engage the mother.  Eleanor Green had rarely worked with a parent who showed such resistance to engaging with the services whilst simultaneously showing signs of engagement and achievement at contact sessions.  The mother had not addressed her own vulnerabilities, which arguably caused harm to her previous children, and must therefore pose a greater risk of harm to the child who has no father to provide a safety net.  There were serious concerns about the mother's ability to function consistently and safely.  The unknowns were vast, due to her failure to engage in any meaningful way with or without the parameters of legal orders.  She therefore supported the care plan for adoption.  

The mother's position

31.      Substantial efforts were made to encourage the mother to attend the hearing, but without success.  Advocate English met her with an interpreter on 20^th September, 2016, when she expressed these wishes:-

(i)        that she wanted contact with the child between then and the Court hearing;

(ii)       that she would like the child to live with her;

(iii)      that she understood the Court will make a decision about whether the child would be freed for adoption or not and who is to look after the child;

(iv)      that she might attend Court to put her case and give evidence with a view to asking the Court that the child be returned to her; and

(v)       if the Court does free the child for adoption, she did not want the child to have anything to do with her family, including the child's Jersey siblings and grandparents, as it would be too painful for the mother.  Furthermore, in the event of a freeing for adoption order, the mother does not wish to be contacted by the Children's Service or anyone else that has been involved in this case about anything to do with the child, as it would again be too painful to be reminded about the mother's loss. 

The law

32.      In the matter of the T children [2009] JRC 231 is authority that when the Court is considering parallel applications for a care order and a freeing order, it may consider the evidence in the round, rather than dealing with the two respective applications separately, and that is the approach we adopted. 

33.      We had regard to the guidance given in the Court of Appeal judgment of Re F and G No (2) [2010] JCA 051 in terms of the threshold criteria, the welfare test and freeing the child for adoption.  The law is now well settled and need not be repeated here, save a set out below. 

34.      The severance of family ties inherent in adoption without parental consent is at the extreme end of the Court's powers to intervene in family life.  In the matter of M [2013] JRC 234 applied the principles established by the Supreme Court in Re B (A Child) [2013] UKSC 33, and by the English Court of Appeal in Re B-S (Children) [2013] EWCA Civ 1146.  Although the statute in Jersey with regard to adoption is now significantly different from that in England and Wales, In the matter of M confirms that the Court should only make an order seeking to sever the relationship between a parent and child where it is necessary within the meaning of the European Convention to do so in order to protect the interests of the child.  

35.      At paragraph 170 of In the matter of M, the Court considers the issue of "non-consensual" adoption and refers to paragraph 22 of the Supreme court judgment that says this:-

"The language used in Re B is striking.  Different words and phrases are used, but the message is clear.  Orders contemplating non-consensual adoption - care orders with a plan for adoption, placement orders and adoption orders - are 'a very extreme thing, a last resort', only to be made where 'nothing else will do', where 'no other course is possible in [the child's] interests', they are 'the most extreme option' a 'last resort - when all else fails', to be made 'only in exceptional circumstances and where motivated by overriding requirements pertaining to the child's welfare, in short where nothing else will do'; see Re B paras 74, 76, 77, 82, 104, 130, 135, 145, 198, 215."

36.      In Re W (A Child) [2016] EWCA Civ 793, the Court confirms the approach used in Re B whilst cautioning against the use of the phrase "nothing else will do" without linking it to a thorough overall evaluation of the welfare of the child;

"Since the phrase 'nothing else will do' was first coined in the context of public law orders for the protection of children by the Supreme Court in Re B, judges in both the High Court and Court of Appeal have cautioned professionals and courts to ensure that the phrase is applied so that it is tied to the welfare of the child ... The phrase is meaningless and potentially dangerous if it is applied as some freestanding, shortcut test divorced from, or even in place of, an overall evaluation of the child's welfare.  Used properly, as Baroness Hale explained, the phrase 'nothing else will do' is no more, nor no less, than a useful distillation of the proportionality and necessity test as embodied in the ECHR and reflect in the need to afford paramount consideration to the welfare of the child throughout her lifetime."

37.      In the matter of M (paragraph 172) further endorsed three important points emphasised in Re B:-

"i.       the child's interests include being brought up by the natural family, ideally by the natural parents, or at least one of them, unless the overriding requirements of the child's welfare make that not possible;

ii.        the Court must consider all the options before coming to a decision; and

iii.       before making an adoption order the Court must be satisfied that there is no practical way of the authorities providing the requisite assistance and support and Judges must explore rigorously whether a Local Authority is seeking a 'Placement Order' because resource issues make it unwilling to provide the necessary support."

38.      In the matter of M (paragraph 174) also confirms that in every case where the Court is being asked to approve a care plan for adoption without parental consent, the following guidance set out by the Court of Appeal in Re B should be applied:

(i)        the need for proper evidence from the local authority and the guardian which addresses all the options which are realistically possible and contains an analysis of the arguments for and against each option; and

(ii)       an adequately reasoned judgment which includes a 'global holistic evaluation of all the options'.

Decision

39.      Diane Burgess was on long term sick leave and therefore unable to attend the hearing, but we had the benefit of her two detailed reports and the evidence and advice of her manager, Ms Ceri Owens, Eleanor Green and Dr Carritt-Baker.  We also had the benefit of the advice of the amicus curiae, Advocate English. 

40.      We agreed with the Minister and Advocate Davies for the child that the threshold criteria was met - namely that the child would be likely to suffer significant harm attributable to the care likely to be given to her if no order was made, not being what it would be reasonable to expect a parent to give the child and this for the reasons set out in the final threshold document.  In summary, the relevant factors were:-

(i)        the evidence of the mother's violent treatment of the children from her marriage to Mr B and the Court restricting her to indirect contact;

(ii)       her conviction for grave and criminal assault;

(iii)      the mother's concealment of the pregnancy, exposing the child to serious risk, if not death if she had given birth to her alone;

(iv)      the mother's failure to take any steps to prepare for the birth of the child;

(v)       her aggressive and abusive conduct at contact sessions;

(vi)      her refusal to attend either the St Michael's Fellowship unit or the unit in Midvale Road;

(vii)     her failure to engage with the Children's Service and other agencies;

(viii)    her refusal to name the father of the child and to give any information about the members of her family, thus preventing the Children's Service from exploring the possibility of others assisting in the care of the child;

(ix)      her continued refusal to accept help and medical advice in respect of the child's needs;

(x)       her lifestyle;

(xi)      her inability to put the child's needs before her own;

(xii)     her failure to show a willingness to change for the sake of the child.  

41.      Diane Burgess, Eleanor Green and Advocate English had set out the options available to the Court with the factors for and against each option.  Those options were:-

(i)        No order, which would result in the child being placed back with the mother. 

(ii)       A supervision order, which would again result in the child being placed back with the mother. 

(iii)      A care order, with the child being placed back with the mother.

(iv)      A care order with the child being placed with foster carers for the foreseeable future. 

(v)       A care order, combined with an order freeing the child for adoption, allowing the child to be permanently placed with adoptive parents. 

42.      The Court could not countenance any order which would result in the child being placed back with the mother, who would be homeless (it not being possible for the child to be housed at the Homeless Shelter) and without any means of support, and with all the risks to the child identified above. 

43.      The mother's refusal to engage with the Children's Service would mean that they would be unable to protect the child from those risks.  To allow that to happen would, in the view of the Court, be grossly irresponsible. 

44.      The real choice was between the child being placed in foster care or a residential unit for the foreseeable future and potentially the whole of her childhood, or being given permanence through adoption.  The former would no doubt suit the mother, and would allow her to continue with her weekly contact, but it would condemn the child to a future which was described to Re LRP (A Child) (Care Proceedings - Placement Order) [2013] EWHC 3974 (Fam) in this way:-

"Long term foster care is an extraordinarily precarious legal framework for any child, particularly one as young as LRP.  Foster placements, long or short term, do not provide legal security.  They can and often do come to an end.  Children in long term care may find themselves moved from one home to another sometimes for seemingly inexplicable reasons.  Long term foster parents are not expected to be fully committed to a child in the same way as adoptive parents.  Most importantly of all in the current context, a long term foster child does not have the same and enduring sense of belonging within a family as does a child who has been adopted.  There is no way in which a long term foster child can count on the permanency, predictability and enduring quality of his placement as can a child who has been adopted."

45.      Advocate English, putting forward every possible argument that could be put forward on behalf of the mother, suggested the Court might consider some kind of "unless order", the purpose of which would be to give the mother a final opportunity to accept a mother and child placement and to undertake therapy for herself.  If she were to agree, it might, he said, clear up some of the uncertainties as to her parenting capacity.  A variant of that would be an order allowing the Children's Service to create a unit in Jersey equivalent to that of the St Michael's Fellowship for the mother and the child (presumably on the assumption that the mother would attend such a unit). 

46.      We did not think it is open to the Court to make some kind of unless order.  It could reject the care plan if it disagreed with it or if the care plan was inchoate, and send the Minister away to re-think the care plan, but this was a care plan with which the Court did agree and which was choate.  Any delay in the Court making an appropriate order would be prejudicial to the child (Article 2(2) of the Children (Jersey) Law 2002-"the Children Law") and it would be a delay made entirely for the benefit of the mother, who had refused legal representation, had not attended the hearing to ask for any such order and who had shown not the slightest sign that she might accept such a placement. 

47.      As to the alternative, the Children's Service had indeed given consideration to the creation of such a unit in Jersey for the mother, but it is a highly specialised unit which would need time to create and to staff and this for a mother who had refused to attend either St Michael's Fellowship or the unit at Midvale Road.  As the guardian said, it would be quite disproportionate and unreasonable to expect the Children's Service to create such a unit in the circumstances of this case.  

48.      Eschewing the phrase "Nothing else will do", the Court had no hesitation in concluding that affording paramount consideration to the welfare of the child (Article 2(1) of the Children Law), it was both proportionate and necessary for her to be freed for adoption, so that she could find permanence with an adoptive family. 

49.      That left the issue of the mother's consent, which had not been given to the child being freed for adoption.  That consent could be dispensed with under any of the grounds set out in Article 13(2) of the Adoption (Jersey) Law 1961 ("the Adoption Law") the following of which was relevant:-

"The grounds ..... are that the parent ....

(b)       is withholding .... her agreement unreasonably".

50.      As the Jersey Court of Appeal held in F and G, the test is an objective one; quoting from paragraph 80:-

"80     The Royal Court turned next to consider whether the mother was withholding her consent unreasonably (the father having consented).  It relied on the explanation of this test as described by this Court at paragraphs 26-29 of Re JS and BS [2005] JRC 108 and it applied the principles there set out.  In particular as it noted, the test is an objective one.  A reasonable parent will give great weight to what is best for the child (see the observations of Lord Denning MR in Re I [1962] 106 LOS JO 611 approved in Re " [1971] 2 All ER 49) but a Court must be careful not simply to substitute its own opinion for that of the parent.  As the Royal Court put it:-

'The question is whether the parental refusal comes within the band of possible reasonable decisions, not whether it is right or mistaken.  There is a band of decisions within which no court should seek to replace the individual's judgment with its own'. [para 18]

81       Helpful in this context are the observations of Steyn and Hoffmann LLJ in Re C (A Minor) (Adoption: Parental Agreement: Contract) [1993] 2 FLR at 272 as to the test:-

'Whether, having regard to the evidence and applying the current values of our society, the advantages for adoption of the welfare of the child appear sufficiently strong to justify overriding the views and interests of the objecting parent or parents.  The reasonable parent is only a piece of machinery invented to provide the answer to this question.'"

51.      A reasonable parent, not able to safely parent a child or to demonstrate a willingness and ability to change within the child's timescale, would not in these circumstances condemn that child to the precarious framework of long-term foster care so that the parent could maintain contact with the child, thus depriving the child of the chance of permanence through adoption. 

52.      We concluded, therefore, that objectively, the mother was withholding her consent unreasonably and we therefore dispensed with it. 

53.      We were satisfied, pursuant to Article 12(3) of the Adoption Law, that in dispensing with the mother's consent, it was likely that the child would be placed for adoption - indeed the evidence was that adoption could be achieved by the end of this year.  In relation to Article 12(7) of the Adoption Law, there was no one before the Court claiming to be the father of the child. 

54.      In conclusion, the Court, having scrutinised the proposals for contact in the care plan and having heard the parties' comments on them:-

(i)        declared itself satisfied that the threshold criteria had been met within the meaning of Article 24 of the Children Law;

(ii)       approved the care plan and made a final order committing the child to the care of the Minister;

(iii)      ordered that the child be declared free for adoption pursuant to Article 12(1)(a) of the Adoption Law; and

(iv)      Requested the Minister to provide the mother with a translation of this judgment. 

55.      Finally, the Court commended Diane Burgess for her exemplary work on this very difficult case. 

Authorities

Children Rules 2005.

In the matter of Charlie (Care order) [2016] JRC 082.

In the matter of the T children [2009] JRC 231.

Re F and G No (2) [2010] JCA 051.

In the matter of M [2013] JRC 234.

Re B (A Child) [2013] UKSC 33.

Re B-S (Children) [2013] EWCA Civ 1146.

In Re W (A Child) [2016] EWCA Civ 793.

Re LRP (A Child) (Care Proceedings - Placement Order) [2013] EWHC 3974 (Fam).

Children (Jersey) Law 2002.

Adoption (Jersey) Law 1961.