Re C (Recognition of Nigerian Adoption)
[2025] EWHC 204 (Fam) · High Court (Family Division)
What happened: A child adopted in Nigeria remained there while proceedings in England addressed recognition of the adoption and related immigration difficulties. An adoption order made abroad does not always have the same legal effect here automatically. The court therefore had to consider whether the family's relationship could be recognised despite a problem with one of the traditional legal requirements.
What the court decided: The court recognised the adoption. Although the usual condition about domicile, a person's legally recognised permanent home, was not satisfied, it found that refusing recognition would interfere disproportionately with family life under Article 8 in these circumstances.
Why it matters to adoptees: For an intercountry adoptee, the documents showing who their legal parents are may be treated differently in different countries. That uncertainty can affect family life and the ability to establish legal status. This case explains one situation in which the English court recognised an overseas adoption despite a technical obstacle. Recognition of an adoption is still a separate question from citizenship or permission to enter the UK, and this outcome does not automatically extend to other overseas orders.
Later treatment not comprehensively reviewed
Read with Re X [2026] EWHC 638 (Fam). Wider later treatment not comprehensively reviewed.
Limitations: Recognition is distinct from citizenship or permission to enter the UK. This fact specific decision does not automatically validate every overseas adoption.
Case details and sources
Adoptee involvement: The child was not a party; the judge explained this limitation and considered her wishes through the available evidence.
Remedy sought: Recognition granted.
Legal route: Application to recognise an overseas adoption
Judgments in this case
- [2025] EWHC 204 (Fam) · High Court (Family Division) · 2025-02-03 · Judgment
Sources checked
- Judgment text reproduced by CaseNode (opens in a new tab)
paragraphs 5, 53–64 · Judgment reproduction
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