C (Children) (Revocation of Placement Orders)

C (Children) (Revocation of Placement Orders)

[2020] EWCA Civ 1598 · Court of Appeal

What happened: A mother made substantial improvements in her life after placement orders had been made for three of her children. She was allowed to apply to revoke those orders, meaning she could ask the court to stop the existing legal authority to place them for adoption. A further child remained in her care. She appealed when the court nevertheless refused to revoke the older children's placement orders.

What the court decided: The Court of Appeal dismissed her appeal. The placement orders remained in force. The decision considered both the changes in the mother's circumstances and the assessment of the older children's needs and risks; improvement alone did not determine the outcome.

Why it matters to adoptees: An adoptee may ask why adoption proceeded when a parent later cared for another child or their circumstances improved. This case shows how that situation can arise and why the timing and individual assessments matter. It does not establish that parental change is irrelevant. These were placement orders before adoption, not applications to reverse completed adoptions, and the distinction affects the available legal route.

Limitations: Concerns placement orders before adoption, not reversal of completed adoption orders. Does not establish that parental improvements are irrelevant.