In Re W (Minors) (Social Worker: Disclosure); Re W (Disclosure to Police): CA 26 Mar 1998

A social worker may disclose admissions made during investigation into child abuse, to the police without the court’s permission, where the information had not been incorporated in the welfare report filed at the court. The rule (against disclosure) applies only to documents which have actually been filed with the court and ‘protects only the pieces of paper and not the contents’.


Butler-Sloss LJ, Mummery LJ, Judge LJ


Times 08-Apr-1998, [1998] 2 FLR 135, [1998] EWCA Civ 553, [1999] 1 WLR 205, [1998] 2 All ER 801, [1998] 2 FCR 405, [1998] Fam Law 387




Family Proceedings Rules 1991 4.23


England and Wales

Cited by:

CitedKent County Council v The Mother, The Father, B (By Her Children’s Guardian); Re B (A Child) (Disclosure) FD 19-Mar-2004
The council had taken the applicant’s children into care alleging that the mother had harmed them. In the light of the subsequent cases casting doubt on such findings, the mother sought the return of her children. She applied now that the hearings . .
CitedDoctor A and Others v Ward and Another FD 8-Jan-2010
Parents wished to publicise the way care proceedings had been handled, naming the doctors, social workers and experts some of whom had been criticised. Their names had been shown as initials so far, and interim contra mundum orders had been made . .
Lists of cited by and citing cases may be incomplete.

Children, Litigation Practice

Updated: 19 May 2022; Ref: scu.82278