Re N (Children: Revocation of Placement Orders)

Re N (Children: Revocation of Placement Orders)

[2023] EWCA Civ 1352 · Court of Appeal

What happened: A mother sought to revoke placement orders for two children following changes in her circumstances. She had permission to make the application, but the court refused revocation and declined to order a further independent social work assessment. She appealed those decisions, raising questions about the evidence and the approach to reconsidering the children’s future.

What the court decided: The Court of Appeal dismissed the appeal, leaving the placement orders in place. It explained that, once permission to seek revocation has been granted, the substantive decision is about what the children’s welfare now requires. The court must not keep a placement order that is no longer justified, but a realistic possibility of family care does not automatically establish that revocation is in the children’s interests.

Why it matters to adoptees: The judgment explains both the possibility and the limits of reopening a plan for adoption. Changed family circumstances can matter, but permission to apply and success on the application are different stages. It is useful alongside successful appeals because it shows what remains to be established when a family asks the court to reconsider, and why a previous placement order must still be justified in the circumstances at that later time.

Limitations: Unsuccessful substantive placement-order challenge. Not a completed adoption case. Cross-reference Re C [2020] EWCA Civ 1598; no exhaustive later treatment review.