The mother had failed in her application to have set aside a special guardianship order made in favour of the child’s grandmother. The judge had held that the change in her circumstances was not significant.
Held: Her appeal succeeded. The statutes contained inconsistencies as to the levels of change required to support an application, and the court should apply the standards identified in In re M. That did not require the change in circumstances to be significant, but these were in any event.
Ward LJ, Wilson LJ
 EWCA Civ 300,  Fam Law 598,  2 FLR 696
Children Act 1989 14D(5)
England and Wales
Cited – Warwickshire County Council v M and others CA 1-Nov-2007
The judge had granted the mother leave to apply for revocation of placement orders. The authority appealed. The mother argued that once a change of circumstances was shown, the court was obliged to give leave to apply.
Held: The judge was not . .
Cited – Re A (A Minor), Re TL v Coventry City Council; CC v A, by her Children’s Guardian CA 21-Dec-2007
The foster mother of a baby promptly indicated a wish to adopt her. Following four months of assessment Coventry informed her that, for reasons which she wished to challenge, her adoption of the baby would be unsuitable. Three days prior to so . .
Lists of cited by and citing cases may be incomplete.
Updated: 01 November 2021; Ref: scu.406534