the child's relatives, or of any such person
, to provide the child with a secure environment in which the child can develop, and otherwise to meet the child's needs”. 19.The Respondents seek to meet these points by reference to the following statute and case law. 20.First, Ms Anning and Ms Kelly make the powerful point that the mother’s birth family are not ‘family’ and are not ‘relatives’ of F, and have not been for many years. They point to the fact that Sections 46 and Section 67 of the ACA 2002 have the combined effect of having extinguished the parental responsibility of the mother’s birth parents at the time of her adoption, and that the mother is and has been since her adoption order treated in law as if born to Mr M and Ms N and no other person. When the adoption order was made in relation to the mother, the court effectively approved and actioned the ‘permanent severance of family ties’ (YC v United Kingdom (2012) 55 EHRR 967) between the mother and her biological family, creating new a new family for the rest of her life. 21.Secondly, even if (contrary to that primary submission) the birth family could be said to be ‘family’ because of their blood ties: “… …there are no provisions of either the CA 1989 or the ACA 2002, the AAR 2005, or associated Practice Direction, which absolutely