PK v Mr & Mrs K
[2015] EWHC 2316 (Fam) · High Court of Justice, Family Division
What happened: A 14-year-old adopted person applied in her own name to end the adoption order made when she was nearly four. She also wanted to use her biological mother's surname. The application placed the young person's own wishes about family and identity at the centre of the proceedings, rather than treating her solely as the subject of an application brought by adults.
What the court decided: The High Court granted both requests: it revoked the adoption order and allowed the surname change. That was the historical outcome. However, the Court of Appeal in X and Y in 2025 said PK had been wrongly decided, and the Supreme Court in 2026 rejected the general protective power relied on for this kind of revocation.
Why it matters to adoptees: The case may resonate with adoptees who want legal recognition of their own understanding of family. It documents a young person asking the court to act on that understanding. But it would be misleading to suggest that the same application is available now on the strength of this decision. The young person's successful outcome and the later rejection of the legal route must be explained together.
Reasoning rejected in later judgments
X and Y (2025), paragraph 68, says PK was wrongly decided. The 2026 Supreme Court judgment rejects the inherent jurisdiction approach.
Limitations: The historical order and the later rejection of its jurisdictional reasoning are separate matters.
Case details and sources
Adoptee involvement: Direct applicant; competent to instruct
Remedy sought: Revoke adoption and change surname
Legal route: First-instance asserted inherent jurisdiction
Judgments in this case
- [2015] EWHC 2316 (Fam) · High Court, Family Division · 2015-07-31 · First-instance inherent-jurisdiction application
Sources checked
- X and Y (2026): judgment and discussion of earlier cases (opens in a new tab)
paragraph 50; read with the 2025 Court of Appeal judgment · Later judgment - X and Y (2025): Court of Appeal judgment (opens in a new tab)
paragraphs 53 and 68 · Later judgment
Review scope: Original database extraction checked against X and Y (2025), paragraph 53, and the later rejection of inherent revocation in X and Y (2026). Original judgment not freshly reviewed.
Human verification pending. Entry: CASE-0007.