(Court of Appeal, Rix, Black, Lewison LJJ, 14 November 2012)
The 2-year-old child had been in foster care for her entire life and had only supervised contact with her parents. The mother had been known to the local authority for a number of years and was found to be a vulnerable and complex person. Her previous child, who was born as the result of a relationship between the mother and her step-father, was removed from her care. During the relationship the mother was physically and sexually abused by her step-father and had a number of abortions. She now suffered from somatisation disorder.
The father had a significant criminal history and four children from a previous relationship with whom he had little involvement. Both parents were found to be unco-operative and, at times, deceitful, with professionals.
The local authority care plan for the 2-year-old child to be adopted was approved by the judge and a final care order was granted. The parents appealed.
The judge had not erred in his identification of aspects of harm the child was at risk from nor from his treatment of that harm as significant. He had been entitled to conclude that the threshold criteria were satisfied and to make a final care order.