In Oxfordshire County Council, v M & Ors [2026] EWFC 228 (B) the court considered whether protective orders could safely support reunification where a mother continued to minimise the father’s sexual offending and domestic abuse risks and required substantial support to meet her child’s needs consistently.

HHJ Eleanor Owens made a care order for A, who had been living with his aunt and uncle since March 2026, after concluding that a return to his mother’s care would expose him to unacceptable risks of sexual harm, domestic abuse and neglect. The father had a history of sexual offending, repeated breaches of Sexual Harm Prevention Orders and domestic abuse towards the mother. Despite knowing this history, the mother continued to minimise the risks he posed and had enabled breaches of restrictions. Assessments also identified difficulties in her ability to recognise danger, prioritise A’s needs and provide safe care without oversight. Although both parents offered to comply with protective orders, the court found that such measures would be insufficient because their effectiveness depended on the mother’s ability and willingness to recognise and report breaches. A’s welfare therefore required him to remain in his kinship placement under a care order.

Eleanor Howard acted for the Applicant Local Authority. Alex Forbes, instructed by Oxford Law Group, acted for the First Respondent Mother. James Turner, instructed by Truemans, acted for A, acting through the Children’s Guardian.


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