Re S (Placement Order Contact)
[2025] EWCA Civ 823 · Court of Appeal
What happened: There was agreement that a child being placed for adoption should continue to see siblings. The dispute was whether that contact needed to be protected by a court order. The appeal raised questions about how to assess the relationship, what future contact should look like, and whether recording an intention was enough in the circumstances.
What the court decided: The Court of Appeal dismissed the appeal, so it did not require the requested contact order. Nevertheless, it stressed that decisions must address the individual child's relationships and welfare throughout life. The arrangements in another case could not simply be adopted as a standard contact schedule.
Why it matters to adoptees: For adoptees, the difference between a promise of contact and contact that actually continues can be substantial. This case helps frame questions about how sibling relationships were assessed and why a particular form of protection was chosen. Its guidance is useful even though the appeal failed. It does not establish an automatic entitlement to a contact order, a fixed number of visits, or unchanged arrangements after a final adoption order.
Later treatment not comprehensively reviewed
Later 2026 contact authorities were identified during discovery but not fully reviewed; this entry does not claim to exhaust current law.
Limitations: No automatic right to a contact order or fixed frequency. Guidance supporting contact must not be presented as a successful appeal.
Case details and sources
Adoptee involvement: Child represented through a guardian; not an adult adoptee’s application.
Remedy sought: Refusal to make a contact order upheld.
Legal route: Appeal concerning section 26 contact
Judgments in this case
- [2025] EWCA Civ 823 · Court of Appeal · 2025-07-01 · Judgment
Sources checked
- Official Court of Appeal judgment (opens in a new tab)
paragraphs 68–87 · Judgment
Review scope: Official reasoning and dismissal checked. Submissions distinguished from judicial conclusions; no exhaustive later treatment review.
Human verification pending. Entry: CASE-NEW-008.