Stephen Crispin in Oxfordshire County Council v M & Ors [2026] EWFC 192 (B)
17th Jul 2026 | Cases
Stephen Crispin acted for the Applicant Local Authority in Oxfordshire County Council v M & Ors [2026] EWFC 192 (B), a decision which demonstrates the careful application of the “nothing else will do” principle where parents relied on recent changes, but the court held those changes were too recent and insufficiently established to outweigh long-standing concerns.
HHJ Eleanor Owens granted a care order and placement order in respect of a one-year-old child, concluding that adoption was the only realistic option despite both parents’ opposition. The judgment provides a detailed analysis of the welfare balancing exercise where parents rely on recent improvements to address historic concerns.
Although both parents had begun engaging with mental health support and asserted that they had separated, the court found these developments were too recent to demonstrate sustained change. Particular weight was placed on the parents’ unresolved mental health difficulties, domestic abuse, substance misuse, inconsistent engagement with professionals, and inability to prioritise the child’s needs. Applying the principles in Re B-S, Re H-W and Re J, the court held that placement with either or both parents would expose the child to an unacceptable risk of harm and that only adoption could provide the permanence and stability required. The judgment offers a careful illustration of the holistic welfare and proportionality analysis required in placement order applications.
