Good morning, welcome everybody very pleased to welcome you to today's session through Data Law. My name's Safta Mahmoud and as you know, then I'm going through a number of issues with you in these discourse, which is a Of course, each approximately 30 minutes in length three sessions. And we're looking at the area surrounding expectations in relation to assessing family and friends who have put forward in Children proceedings in the last session. You remember I spent a fair bit of time going through the judicial guidance in terms of the best practice guidance which has recently been available. The statutory guidance by the DFT. We looked at practice direction 12 A and also particularly when it comes to special gunship orders About the need to comply with the case of VPs of 2018 and particularly the interim family justice guys about assessing and exploring a family and friends options at the earliest opportunity today. What I'm going to do is developing quite significantly the position with the case law that's developed in relation to exploring friends and family options. As I've been looking specifically at some of the leading authorities in this area, many of you will be familiar with cases like 3B 2013 BBS of 2013 Wide. Of 2016, for example. And then one of the more significant cases which really looks specifically at the duties upon local authorities when it comes to family and friends. The case of the age of 2019. I've been taking you through that and some of the developments in so far as that's concerned and how this ties in with the adoption and Children are particularly when you the specter of doctors identified. So I'm looking at the law as of October 2021 and I've also put the copyright acknowledgment here for you acknowledging crown copyright and also def as a corporate author. So, what I want to start with then is remind you about this case of re B which as many of you were noise of a significant court of Appeal, the Supreme Court decision some years ago. It's a very, very lengthy judgment as you know, it goes through a number of key issues in Children cases. It looks at, for example, threshold. It looks at like a lot of harm. It looks at the issue of fyi fabricated inducing sensitization disorder, threshold, generally culpability. So there's a number of issues there, but also it looked specifically at the position with plans for adoption. As many of you will know, there was references throughout this judgment to the fact that adoption by its very nature is clearly A major corn in order. Of course it involves the complete 7th of the parental responsibility that the parents and other people with PR will have for that child. So it's a complete legal transplant of parental responsibility. And therefore many of the references throughout three B as you know, is there are references to the fact that adoption order should only be made exceptionally when nothing else will do so many of you will know about that. But as well develop the discussion this morning, you'll see that some practitioners sadly have taken what we be was telling us wrong in that some practitioners quite wrongly and interpreted really be as meaning that adoption was almost a thing of the past. That really adoption shouldn't be used anymore. And that's not what everybody was saying, ruby is very much emphasizing what the nature of an adoption order is given this significant change in so far as poetry responsibility. And if an adoption order is made for a child, it should be made when nothing else will do when all other realistic options have been explored and none of those are going to be meeting the child's best interest and therefore with the child's welfare and not just during their childhood, but indeed into adulthood and therefore for the rest of their life, adoption is what's required and that's really how you need to try and understand this. Okay, So sometimes you will have cases whereby there are a number of options that explored, but actually on the facts, adoption is the one order which is required for that child given the particular circumstances of that child. Okay, so those are some of the key elements and tied in with that. You've got the other case of RE Bs. Now again, many of you will know about re Bs. The case itself was a very complicated case which involved an application by the mother for leave to oppose the making of the adoption orders relating to her two Children pursued a Section 47 of the adoption of Children Act of 2000 and two. The leaning judgments handed down by the President of Family Division at the time. Sir James Mumbi and his lordship spent a lot of time helping us to understand how do you actually Test in the section 47 perhaps I'll leave your poles and then the actual adoption thereafter operates in practice about the need to change to show changes circumstances about the need them to look at child welfare, which then is broken down into two further parts. We're looking at the impact upon the child and also you're looking at the prospects of success. So very important. But re Bs is also a case which reminds us uh and it doesn't make new law and say this, it reminds us about this. So it doesn't make new law in making sure that when local authorities, when guardians, when the courts are making decisions, when adoption panels and agency decision makers are considering recommendations and decisions, that they must take into account all realistic options, which doesn't mean that you therefore apply linear approach. You apply holistic approach as you know, that doesn't mean as we'll see later, that you have to assess every time. It doesn't mean that you have to make sure that no stone is left unturned. It doesn't say that at all. It emphasizes the words, the word realistic option. Okay, and again, I'm going to emphasis that when we look at some of the other issues and again, this then ties in with the discussion I had with you in the first session about need therefore to explore friends and family options as early as possible. So like I said, because of the misconceptions that people had with both three B and also re Bs in that some practitioners thought that it meant that adoption was no longer a preferred option or one option. And it was really a thing of the past as the president referred to it and we B. S. Some practitioners were missing. I missed some Interpreting that by thinking that it meant that you have to consider every option and therefore if you've got people who are being put forward literally at the 11th hour at court, that was imperative that the local authority assessed them in the court therefore needed to adjourn because that's what was being suggested. We are was decided very Soon thereafter and this was decided and handed down on 16 December 2014. Angelini judgment was once again handed down by the then President of Family division, Sir James Mumbi. And one of the things his lordship did emphasis in this case was just that was that actually BBS hasn't changed the law. It's reminding us of what we should have been doing and have been doing for many years, we be is yes emphasizing district nature adoption but his lordship emphasis in particular that if adoption is in the child's best interest and that is the right plan. Local authorities, guardians. The court should not shy away from that. And if it means during proceedings that parents and other family members and identified persons are ruled out as carers, then that needs to be done. And if adoption is the plan that it needs to be progressed and we shouldn't shy away from that. And there was almost this idea that the President said that that this idea that you must be assessing everybody that's been put forward and that's not the case at all. And also the president criticize some of the lawyers in this case by emphasizing that in terms of the balance sheet approach under ebs that doesn't have to be a strict tabular balance sheet. As long as the various realistic options explored, sort of holistic evaluation as opposed to a living evaluation. That's what's important. So again, you can see this case is very, very important. So less than really discuss further this idea of what do you mean by when nothing else will do because as you know, that's where family members are being put forward sometimes later on in the proceedings despite what have been discussing with you sometimes that will happen for a number of reasons. Sometimes it's not because the family member didn't want to be pulled forward. They just simply don't know And later in the third session, I'm going to be going through some cases with you where sometimes family members come forward, who simply didn't even know that that does. There was a child and their grandparents for example. So in re W 20 16, this was a quarter of your decision leading judgment by Law Justice Macfarlane as he was then. And it was a case where by his lordship emphasized a number of key things which needed exploring and addressing in these matters. Which is what is the approach to be taken by the court in terms of a child's long term welfare. Where as in this case, if you've got a child who has now become fully settled in the perspective adoptive home. And then late in the day there is a viable family placement which identified what should happen should touch hard be removed from the uh perspective adoptive home that they have now become settled and be placed in the family placement for which there has been this far below replacement. Is this what we mean by when nothing else will do when all else fails? And this is where his lordship then said that one needs to look at the application of the 20 13 Supreme Court Decision. And we B by what do you mean by nothing else will do? And thirdly whether people whose relationships force within that to be considered under the adoption Children in 2002, 6 and 1 4th, which is you're looking at the feasibility of the child remaining a member of the original family and the wishes and feelings and the relationship. Are you limited to just looking at blood relatives? Or should it also include prospective adopters? So if the child has in this case has become settled in the home of a prospective doctor, I entitled for the purpose of sub paragraph F to take into account that relationship as well when it comes to plans for adoption. And also whether the court needs to expressly undertaken evaluation of context of the human rights act in circumstances and if so what? Right? So in case. So these are obviously very very significant questions therefore, which we all needed answering and hence why I'm so glad that we w was decided to help us with this. So on the facts, it's a very lengthy case, this one and I won't have time to go through too much on this session. But just to emphasize this was a case whereby you had a first child who the parents had who sadly they could not meet the needs of and that child was removed and placed with deep paternal grandparents. And so the first child I should say was removed. And in fact made subject to care and placement order. In fact placed for adoption, I should say. But then Children, parents went on and had another child and it was that child that actually was placed with the paternal grandparents had a positive viability assessment, and they had the child placed with them and then the parents went on and had another child. And what their grandparents wanted to do is because they had the one child placed with them. They sought to see if it is possible for them to have the child who had been placed for adoption, potentially been placed with them as well. So through the father, they sought to have the leave your Poles, although it was the father who is pursuing that on their behalf. And the court decided that actually given the child had been placed with the Prospective doctors now for some 17 months, and obviously had formed a commitment and attachment with them. You can't ignore that fact. Read re B. S of course, did say that the fact that the child has been living with prospective adopters in itself is not a reason to prevent metropole has been granted. But of course it is A factor which cannot be ignored. And therefore, his lordship did say that when we are looking at section one force of paragraph F in terms of the relationship the child has or may continue to have. It's not just of birth, family and blood relatives, it's also of prospective adopters as well. And as you see in a moment, the adoption Children act was amended after this decision to cater for that. But also both the guardian independent social worker were criticized because in their reports, they were identifying the fact that there is a presumption that the child should be brought up by family and should be living with family and his lordships. Actually, there is no such presumption. Um the only presumption if there is the one is the fact that the child's placement should be determined by what's in their best interest in the corners with the principles under the Children Act in the application of that. But there is no presumption that the charges should be brought up by family. Each case, it's on its own facts and you have to look to see whether that's the appropriate order in the circumstances here. On balance. The court did say that despite the fact that there was a positive viability assessment of the grandparents, and despite the fact that they came forward, we be does not want and necessitate in these circumstances using the terms where nothing else will do when all else fails, that you must than nd placement of prospective doctors and we turned a child to the kot of the family. One has to weigh up what's in the child's best interest, if you do have to look at the fact that child has built up that relationship, the family, so you're the prospective adopters and that is potentially going to be the child's forever home. And then you got to balance that against placement with family and therefore the positives of that and also the the negatives and the drawbacks of that and therefore effectively carry out that balancing balanced approach and referred to in re Bs and under facts here, court was of the view that it would be a disproportionate step to remove the child. And in fact, of course, satisfied that adoption was in this child's best interests, those particular adopters. So you can see it's a very, very important case. And again, to me, this emphasis is also the fact that those of you acting for parents very, very important to make sure if friends and family options are going to be explored, you must make sure that those friends and family options explored and they are put forward at the earliest opportunity because of course if they come forward very late, as in this case, there is no guarantee whatsoever that day will be successful in. They pledged for having a child placed with them. And this was also emphasized in a later case of re L. And others. This was a 2017 decision handed down by Mr Justice Keon and this was a case where by you had on the mother's side, you had three family members who had been put forward and there had been viability assessments are done of them all which were negative, none of them sought to challenge those at that stage, even though there was a provision for them to do so. As for father, he didn't put anybody forward until later on in the proceedings and quite close to the higher age. He in fact, at that stage, even though he hadn't asked his father, in fact, to put his father forward as a potential carer and his father lived overseas. What was known about his father was that he had been on the well for a period of time. He had suffered from a heart attack and he was separated from the father's mother. And like so, he hadn't been even asked by the fires at that stage. So when and also as for mother, she wished now to have the three persons who had been assessed challenging the viability assessments. His lordship did say that he wanted mother to file a statement setting out what the reasons were for that for them coming forward at that stage, and the basis upon them challenging and under facts here, his lordship didn't allow those challenges to be taken any further. He didn't allow the assessment of the of the paternal grandfather because for The reasons set out specifically in paragraph 12. And this is why his lordship said his lordship emphasized, Sanchez very late challenges to viability assessments, which is what was happening here or the very late identification of family members, which again, is what was happening here will only be countenanced by the family court. If there is exceptionally good reason as to why hitherto, they have not gone forward and the colony sanction them if the assessment of them does not have an adverse effect upon the timetable for determine the future that you now here court was not satisfied that there were good enough reasons for the late challenges to viability as they should have been done much much earlier weeks previously. There's no good reason why there was a later identification of the family members and a part of father. They should have been done much earlier. His lordship said it was his duty. And in fact, the welfare, best interest of the Children of the singers were determined as soon as possible. So again, you can see how this case illustrates the importance of identifying friends and family as early as possible. Proceedings if possible. As we mentioned earlier and then getting those assessments done as early as possible. You can see the significance of why that is so so important and that is also married home in this later case. This case of re hagia care and adoption assessment to wider family. This was a judgment handed down by Mr. Justice Cobb. And what this case looks at is really addressing that key question that I put to yourselves earlier, which has is a local thought required whether by law or by statute or otherwise. Case law. Otherwise, to notify family wider family members of the existence of a subject child or to assess them when they are not being proposed by parents as potential alternative carers and where the parents either, both of them specifically do not wish the wider family to be involved. So that's the question that his lordship wanted to answer. You can see this is a very, very significant question many of you representing local authorities will often have this put to you where you may have a social worker who brings you. And he's saying that there are family members that we've identified. We've got the name of the paternal maternal grandmother, john Cordy aunt. But we've got the mother father forbidding us preventing us from going and approach them. So what's our duty? What do we do? Do we how do we have a duty to assess? Are we there to explore them? How far do we go with this? As you know, those are some of the key key questions that have been asked. And this was a case whereby again, it was a very lengthy judgment and it's one whereby the parents were being assessed and suddenly it wasn't looking positive for them as a placement with them was not becoming a reality. And this is where the local authority had referred the child's case to the agency decision maker with a beauty then seeking approval to pursue and lodge a placement for adoption. But this is where the ADM explored with the social worker what other family members had been identified in its circumstances? And this is where in so far as the maternal side of the family is concerned. Mother had put forward members of the maternal family the new of the existence of this child. But none of them wish to be considered as carers. And so far as the paternal side is concerned, none of them knew, none of them knew about the child. The father hadn't told him and in fact he did not wish his family to be told. At first he was saying that he was embarrassed at first he was also saying that he didn't feel that they would be suitable and he didn't want any of them to know about this. So he was really sent to the social, what can I do wish for them to be told at all. And this is where the local authority lodged the application and part 19 of the FPR now it's a very useful provisions, some of you know which I'll talk about in a bit more detail in the third session which is where if the local authority of the view that it's not a clear cut case that the family should not be told. It's one where they may need to be told from what they know about the family and one shouldn't just going to say so of the father was in this case then they will put to the Judge via Part 19 route as a preemptive application if necessary or even doing proceedings. They were put to the judge position and then invite the judge to then determine as to whether or not the family are to be notified or not. And the local authorities did have details of the paternal family. They were able to identify who they were. And this is where therefore it looked at the issue of do they have a duty to assess the family in these circumstances? Well, this is where his lordship did set out specifically the law on this. His lordship looked at, for Example, the Children active 89, in terms of, say, sections 20 to a three to see of the Children, for example, about place where Children. His lordship looked at the statue guidance that I mentioned earlier. The 20 14 guidance p a lot of practice. Direction 12 A. His lordship looked at the judicial judgments that have been decided in relation to this and ultimately, his lordship took to view that none of the case law in one of the statutory guys, in none of the support of proportion or the primary legislation, does it state that there is an absolute duty placed upon a local authority to inform, consult or sess otherwise consider members of a wider family in all circumstances. So it is not absolute duty to assess. And I think that's really, really important in that regard. And therefore there is no that there is no absolute duty to assess on the paragraph 22 of the judgment. Having had considered these various pieces of legislation, particularly the adoption Children, For example, even section want sub section four subsection for example, there is no absolute duty to assess. And one then had to look at of course the Article eight rights of the father. The right for privacy and family life. He didn't with his family to be identified. But then you got to look at the Article eight rights of the child and the right to respect for privacy and obviously been brought up within family and in a potential family life under paternal Side. So one has to look at that as well in that regard. So, therefore, what is to be done in this situation, what this is where his lordship did say that night would have revealed of the primary legislation and guidance and the case law. The decision was that the local authority did the right thing in that they did bring the matter back before the court for determination of this. Not only existing law required a mandatory due to assess, but the local authority did the right thing. And putting question to the court via the part 19 route in inviting the judge to make a determination as to whether the extended family were to be approached or not. And his lordship did say on the facts for the reasons given uh the family were to be approached. But the judge would give the father time to speak to his parents to tell them about the existence of a child with a view to them coming forward. But if he was unwilling to do that or didn't do that within a finite period of time, then a judge would be invited to social. Can regard you to go and see his family and speech about about the position going forward. Guidance therefore can decor give us in so far as informing the family. Well, if you look at paragraph 49 of his judgment, particularly some very useful pointers in there and that his lordship did say that sometimes there will be instances where maybe there is history of domestic abuse of family abuse in the circumstances where it may be inappropriate for the wider family to be informed. There may be situations where there are issues over cultural, religious aspects. It may be that the child is born out of wedlock. And there could be a lot of shame boom brought upon the mother or the father. For example, if wider family were identified, there could be concerns over mental health or well being of the parent or the child in those circumstances. If disclosure was made. So obviously there are circumstances where it may be inappropriate to inform the wider family. Just simply going to say so of the parent to say, I don't want my family to be told because I don't get on with them or I don't think they're going to be viable or embarrassed that in itself may not in itself be sufficient. And one of the things that his lordship again emphasized was about the need for good practice. So that's very important. Again, as we as identified with you earlier and as his lordship emphasis here, that the family rights group, for example, and also the Department of Education has emphasized the need for early identification of family members. So it comes back to that again to ensure that early assessments are done in those circumstances. With a view to to looking at this. So you can see that the court did wish for the family to be informed which they did. And of course, here, when his family did become aware, then they would need to be if they were, they may say that they don't want wish to be assessed. But of course if they did seek to be assessed and they would be viability assessments of them. But at least then that opportunity would have been had the difficulty, of course, is in the future. If the paternal family were not told and a maternal family didn't know, then that could cause further problems in the future because in the future more so for father, he could then be heavily criticized by his family and indeed soaking mother's family by being told that they were informed. But yet the paternal family were not told. So that could have difficulties. And the other thing the judge did say is of course, even if the paternal family are approached and assuming the assessment of them is negative, then which it's possible. Of course that in itself is not a reason not to approach them because of course at least you'll be getting very vital and necessary life story information which will of course be made available if the child, for example is going to be placed for adoption. So you can see this case highlights a number of key issues that one has to look at when you're looking at uh the position with the that's a consideration of extended wider wider family tied in with that. And I wanted to like see emphasis some of the key provisions in so far as the adoption of Children act is concerned. And this is where many of you will be familiar of course with the adoption of Children act and in particular the welfare Principal under that. So you've got section one subsection two, of course, the welfare of the child is the court's paramount consideration throughout their life. So remember adoption isn't just until 18 is it's for life. So the courts be satisfied. That's the right order for them for really. The rest of their life Delays. Prejudicial to child's welfare. And we've been talking about that earlier, we've talked about the 26 weeks and that's why you'll find out both care and placement proceedings if they are being progressed, we need to be progressed swiftly and often they will be dealt with together. And then there's the welfare check list of course, as I mentioned earlier, Section one subsection for the act, which applies to all decisions relating to adoption until recently until the change that we've had as a result of the Children's Social Worker Act, which I mentioned shortly. The welfare check list. You can see it's somewhat similar to the checklist on the Children, but there are some key differences as well. So you can see It emphasized in particular, looks at looking at the Charles, Ascertainable wishing feelings concerned light of the age and understanding, looking at the child's particular needs. But and this is where a lot of it differs from the Children Act of 89. So you can see here, it emphasizes in particular the likely effect on the child throughout his or her life of season to be a member of the original family becoming adoptive parent. And that's where you can see it's very very important to emphasis to parents uh that there is this heavy duty upon local authorities to ensure that they are parallel planning because they do have to look at there's the effect on the child of seeing that the member be a member of the original family. But remember that doesn't say that one has to assess every time that there is a duty to assess family members. Every time each case obviously sits on its own facts. As we mentioned earlier, one has to also look at paragraph F and like I said, this has recently been changed which I've mentioned. But at this time when the act first came in, it related on into blood relations the relationship with the childhood with relatives. When any other person relation in the court considers agency considers relevant and including a likelihood of that relationship continuing. Okay, so again, that emphasizes parallel planning and then sub paragraph G. Which is the ability and willingness of the child's relatives, the only other such person to provide the child with secure environment. I mean their needs and the wishes of feelings or the relatives of the other person. So you can see all these again are very much emphasizing the need for ah consideration of wider family in that regard. And this is where this this act then has changed the adoption and Children Act was amended as a result of Children's social work Act. So in particular As a result of that we w case of 20 16 that I mentioned the references to the position with the relationship that the child has with relatives and with any other person for the purposes of Section one. Subsection 4. Subsection f. of the is the words with any other person that specifically incorporate with any other with any prospective adopter that a child is so placed. So that's written in now. And that was largely because of the case of www. That 2016 decision that I mentioned court of your decision. Right, let's have a look at another case in which looks at the issue of balancing of realistic options. So this is a recent case handed down Just recently on 11 May of this year, by mr Justice Peel. And a case itself uh was a very difficult case involving factitious disorder, but also it looks at the issue for any consideration of wider family and balancing of realistic options. And it was a case where by the mother of this young child had had a previous child who had been subject proceeding some seven years previously and that previous held, a child of mothers had been removed from mother and placed elsewhere. Mother in the previous proceedings have been found guilty and liable for fi sort of fabricated induced illness whereby she had interfered with the medical care given to the child. And in so far as the court proceedings were concerned, the threshold were met based largely on the, on the concerns that would raise previously. And there was even now concerns that mother would be subjecting her now child who is a subject to proceedings to fi mother was also showing the symptoms of sensitization disorder. Mother was ruled out as a potential carer as a long term care for this charge. He did seek a residential assessment which was ruled out by the court as the court described at time, was not on the side of the mother of the child. The child's needs are pressing. There was very little possibility of positive success and any further delayed by way of allowing mother to a residential would not be in commensurate with the child's best interests. And the expert evidence said that is highly unlikely to achieve sufficient progress to anybody. Assessment to contemplate returning the childhood mother. Mother's mental health is what's going to require prolonged progress far beyond the time scales of residential. So, for those reasons, mother was ruled out and any further assessment for mother was ruled out by whatever residential. So that's where, as you know, local authority then, as part of their power planning, were therefore looking at placement with extended family members. And this is where his lordship specifically referred to the duty upon the local authority to then explore the viability of family and friends options and connecting persons. And this was in line of the case of revenge that I mentioned in so far as that is concerned, whereby his lordship did emphasis that local authorities do of course have a duty to undertake assessments in order to ensure that reasonable placement options are properly before the court. But that duty is not limitless as we age identifies, there is no absolute duty to assess. But there is that requirement to explore the feasibility of an any necessary to carry out appropriate assessments. So, with that in mind, what was done here in terms of exploring and identifying and assessing family members? Well, there was the maternal grandfather who came forward and he sought to be assessed. But what was known about him was this court was told by the local authority that he in fact had no meaningful relationship with the with the child. He had only seen the child briefly a hospital after birth and a couple of occasions thereafter in some remote contact, he had attended family network and care planning meetings. But he had known of the plan for adoption for some months and that was really important to remember that case of Ellen others that I mentioned earlier. His lordship Mr Justice Keehan specifically emphasized that late challenges or late identification of family members will only be counted as the exceptional circumstances in this case. Here. The grandfather, the maternal grandfather knew of the planned for adoption for some once, but he had only now come forward and he hadn't formally put himself forward as a potential carer. So he emerged very late in the day as a result of conversation between himself and the mother a few months beforehand. So you can see that was obviously going to be a major factor here on the facts. So there was a delay in him putting himself forward in the court. Talk to view that himself put himself forward very late in the day his application. If he was granted, then lead to further delay. Further delay would be manifestly contrary to the child's best interests and also on the facts. What was known about the grandfather. There was no realistic prospects of securing the positive assessment in any event. Some weeks stand in line. So therefore his application was in fact rejected on the other facts. So then of course, the court then looks at what other kinship options the local authority have explored and the possibility of kinship placement with any other friends and family options on the facts was not a viable option. The local authority had considered potential family and friends as cares throughout the proceedings, but non was suitable. The family had been away in general terms about the progress of the case. There have been plenty of opportunity to. Local authority argued for them to be putting forward as potential carers, but they had not made themselves available for assessment. So again, you consider the thinking behind that insofar as that's concerned. And therefore the local authority were pursuing a plan for adoption for this child. So local authorities arguing that this child should be able to achieve a sense of permanence emotionally, psychologically and physically within this adoptive setting. None of the parties suggested long term fostering. Other fact, largely because of the child's age, but also given the risk factors associated with have long term fostering in terms of them containing involvement of the mother in particular in the extended family. And the court did take the view that long term fostering wouldn't give this child a sense of permanence which was essential for this child's well being and also mother like I say, would be able to apply for discharge of the killed in the future which carried a risk of uncertainty in this case. Also the faster arrangement would leave open the question of contact which on the facts here was not going to be five election in terms of any significant contact with a child. Given the potential risk that the mother would be proposing to a child going forward. So ultimately the court did decide to go down the route of authorizing adoption in the circumstances and This case. Therefore, you can see it's a very significant one because it not only applies to re h case of 2019 dimension, but it emphasizes and illustrates how there was the notion of parallel planning during the circumstances and why it's very, very important yet again for me to emphasis that friends and family options explored at the earliest opportunity and that door's assessments have done as early as possible. But it's imperative that friends and family options are explored whereby they come forward and sadly here they family did not come forward until sometimes an proceedings. And that's where there's been going to be the further difficulties and complicating features that I mentioned earlier. Okay, so thank you for coming to the end of this session. You can see who has spent a fair bit of time and looking at some of the developing case law on this field. And you can see this is a it's a key issue and there's been a lot of guidance given by a lot of the senior judiciary in many of these cases. Obviously got re BBS. Www. Case. You've got the change in studio option Children act particularly relating to placement, prospective adopters. And then you've got the more recent cases that we've just looked at. Can I? Thank you very much indeed. And I'll speak to you very soon for the next session. Thank you very much. Bye for now.
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