Kent County Council v M & Ors

Kent County Council v M & Ors

Threshold criteria under s31(2) Children Act 1989 are crossed due to significant risk of harm from neglect, poor home conditions, unmanaged medical needs, substance misuse, lack of insight, inability to work with professionals, and absence of support network. Alleged sexual abuse by F not proven on balance of...

Source-derived case information.

Parties
Applicant: Kent County Council; First Respondent: M; Second Respondent: F; Third Respondent: C (a child, by her children’s guardian Jessica Steadman)
Jurisdiction
England and Wales
Judgment Date
03 December 2026
Procedural Posture
Care and Placement Order Proceedings / Judgment After Fact Finding and Welfare Trial
Outcome
Care and placement orders granted; parents' consent dispensed with under s52(1) Adoption and Children Act 2002.
Legal Topics
Care Orders, Placement Orders, Threshold Criteria, Parental Capacity, Child Welfare, Adoption, Proportionality, Learning Disabilities, Substance Misuse, Mental Health
Family Law Child Protection Care Orders Placement Orders Threshold Criteria Parental Capacity Child Welfare Adoption +4 more

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Summary, issues, holding and outcome

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Parties

Kent County Council

Applicant

M

First Respondent

F

Second Respondent

C (a child, by her children’s guardian Jessica Steadman)

Third Respondent

Procedural Posture

Care and Placement Order Proceedings / Judgment After Fact Finding and Welfare Trial

Legal Issues

  1. 1 Whether threshold criteria under s31(2) Children Act 1989 are met
  2. 2 Whether care and placement orders are necessary and proportionate
  3. 3 Whether parents can safely meet child's needs

Ratio Decidendi

Threshold criteria under s31(2) Children Act 1989 are crossed due to significant risk of harm from neglect, poor home conditions, unmanaged medical needs, substance misuse, lack of insight, inability to work with professionals, and absence of support network. Alleged sexual abuse by F not proven on balance of probabilities, but parents cannot safely meet child's needs. Care and placement orders are necessary and proportionate as no lesser order would secure child's welfare.

Court Disposition

Care and placement orders granted; parents' consent dispensed with under s52(1) Adoption and Children Act 2002.

Orders

  • Care order made for C
  • Placement order made for C