Re M (Minors) (Adoption)
[1991] 1 FLR 458 · Court of Appeal
What happened: A father consented to his children's adoption by their stepfather without knowing that their mother was terminally ill. After her death, he sought to challenge the adoption orders. The issue was whether consent given without that crucial information could support the orders. The database relies on the Supreme Court's later account of the case.
What the court decided: The late appeals succeeded. The father's lack of knowledge about the mother's illness undermined his consent, and the adoption orders were set aside. This was an exceptional appeal concerning the basis on which the orders had originally been made, not a general right to reverse adoption following bereavement.
Why it matters to adoptees: A record saying a parent consented may not reveal what they understood when they agreed. This case demonstrates why the information available at the time can matter as much as the existence of a signed agreement. For adoptees trying to understand a family account of consent, it provides a concrete example of the court looking behind that label. The original judgment and subsequent family outcome remain outside the completed review.
Review limitations recorded
Read alongside [2026] UKSC 13: appeal powers are distinct from an inherent power to revoke a valid order on welfare grounds.
Limitations: Exceptional historical appeal; original judgment review pending. Does not establish a general right to reverse adoption following bereavement.
Case details and sources
Adoptee involvement: Application by the birth father.
Remedy sought: Adoption order(s) set aside on appeal.
Legal route: Appeal against completed adoption order(s)
Judgments in this case
- [1991] 1 FLR 458 · Court of Appeal · 1991 · Judgment
Sources checked
- Supreme Court account of historical appeal (opens in a new tab)
Paragraph 81 · Later judgment
Review scope: Facts and outcome checked in [2026] UKSC 13; original report not independently reviewed. Report year retained; precise decision date unverified.
Human verification pending. Entry: CASE-NEW-030.