Aidan Vine KC and Alex Forbes in Confidential Prospective Adopters v BM & Ors [2026] EWHC 907 (Fam)
21st Apr 2026 | Cases
Aidan Vine KC, instructed by Charles Strachan, led Alex Forbes for the First Respondent mother in Confidential Prospective Adopters v BM & Ors [2026] EWHC 907 (Fam); an adoption application following placement order. Judgment considering application by mother for disclosure of full report on the suitability of the applicants to adopt.
This case concerns a three-year-old boy, G, who was placed for adoption with prospective adopters (PA) following a care and placement order made in February 2024. His mother (BM) sought both permission to oppose the adoption and disclosure of the full Annex A report, which assesses the adopters’ suitability. While Part B of the report (relating to the child and birth family) had been disclosed in redacted form, BM argued she required the full report to fairly pursue her application and participate in proceedings.
The court considered the statutory framework under the Adoption and Children Act 2002 and Family Procedure Rules 2010, emphasising the limited role of birth parents at the permission stage and the confidential nature of Annex A reports. Applying established principles on disclosure, the court undertook a balancing exercise between BM’s Article 6 and 8 rights and the child’s welfare and adopters’ privacy.
The court found that the Annex A report was of limited relevance to the preliminary issue of whether BM had demonstrated a change in circumstances. Conversely, disclosure carried risks of harm, including potential instability of the placement and breach of confidentiality. Accordingly, the court refused disclosure of the full Annex A report, concluding that non-disclosure was necessary and proportionate.
This decision likely sets a benchmark for when, and it what circumstances, an order will be made for disclosure of Annex A reports in adoption proceedings where there has been a placement order.
