CA-2025-001731 - [2025] EWCA Civ 1342

Fecha: 23-Oct-2025

Developments post-IRH

Developments post-IRH

27.

Following the filing of the Appellant’s Notice, there was a material development in the case. The paternal grandmother unexpectedly died. At the time, she was caring, with her partner, for N for whom, as I have said, she was the prospective special guardian. We considered it appropriate to consider this latest information under the provisions of CPR 52.21(2)(b) for two reasons:

Its significance to the care plan for N, which had been approved by the judge at the hearing under review; potentially it brings into play the contingency arrangements (i.e., adoption) within that care plan (see §13 above);

ii)

The father relies on this significant development as a material change of circumstances underpinning a recently issued application to the Family Court under section 39 CA 1989 to discharge the care order in respect of N. In that application, the father claims that the paternal grandmother’s partner has informed him that he has no wish to care for N alone. This application is listed for case management directions on 24 October 2025.