[2025] UKUT 308 (AAC)

On 22 September 2021 (two days after the Session), the Appellant emailed the School:

“… I also note that the 'The School of Sexuality' recently visited the school. I have just looked at their website and found multiple examples of partisan opinion presented as fact (especially about gender, trans and social justice issues), and they have an overall approach that I find is lacking in respect for children's privacy, dignity, intelligence and their right to have a personal, sexual development at their own, private pace, undefined by restrictive terminology, theorising, contrived role plays and labelling by adults.

I am not in the least bit convinced that this group are the right people to teach children about anything, let alone the delicate matters of sexuality and sexual relations - not least because they promote material from Netflix…and because they also advise children to go unsupervised, looking for advice from Youtube and even presenting themselves in videos on Tiktok on the subject of Asexuality, for example. This is surely contrary to internet safety guidance - and indeed all common sense!

Tiktok and Youtube are full of deeply unhealthy teen trends regarding mental health and sexuality, and many parents steer their children away from this social media (as our family has chosen to do). It is worrying that the school is employing a company that teaches our children to do otherwise. Can you therefore please explain to me exactly what this company taught about consent at Hatcham College and please direct me to any material and lesson plans they used?”.

The Appellant’s second witness statement said:

“4.

I called the SoSE on the 13th October 2021 because the School had explained they would not be able to show me the resources used to teach my daughter, because of the SoSE’s position not to grant copyright to the school. They seemed to be saying effectively that the matter was out of their hands. I found this surprising and so wanted to understand SoSE’s decision and ask them to reconsider. I did not think it was unreasonable to call an organisation that was paid to deliver services to my daughter’s school, and which taught my daughter, and ask them what they had taught.

…6. During the call I did ask to know what had been taught but I wouldn’t characterise it as “demanding”. I certainly disagreed with Ms. Padalia regarding the idea that she thought it was acceptable to keep resources shown to my daughter secret from me and other parents, but again I don’t think it is fair to characterise it as me getting “very annoyed”.”

On 12 November 2021, the Trust’s CEO emailed the Appellant:

“…I am not prepared to release the names of the facilitators. This again is something which you should request directly from the school of sexuality.”

According to the first First-tier Tribunal witness statement given by D Padalia, of SoSE, she had a 16-minute telephone conversation with the Appellant on 13 November 2021. At this time, D Padalia was SoSE’s Deputy CEO (and subsequently became its CEO). The statement described the conversation as follows:

“I found Ms Page to be quite confrontational…I found her views to be very much contrary to the SSE’s way of working, as well as our approach to inclusive education.

Ms Page was firm that the suggestion of Heteronormativity was not based in fact, and that our activities were illegal and against the law. Due to her confrontational attitude, I tried not to engage with her views, and at no point did I inform her that I would provide her with a copy of a lesson plan. I contest that the call was in any way “civil” in nature.”

The Appellant’s second witness statement set out her concerns about SoSE:

“15.

The point that I was making in referring to the paper at §73 of my first statement was that the paper clearly demonstrates the kind of work the SoSE thinks is acceptable in the classroom and the intentions behind it. In this case it included discussion, potentially with children who are as young as 11, on biological sex as being non-binary, as well as having children draw sexually explicit images to process the trauma of being sent such images – and the SoSE seem to have undertaken this in part because they think the notion of childhood innocence is “false” and because they employ “risky practices”. If this is their practice, then I think it is something that parents should be informed of, and again illustrates why it is necessary for parents to be able to know what was taught by SoSE and who by, so that they can make a decision as to whether to withdraw their children.

16…I believe providers and schools safeguarding procedures are not infallible, and therefore public service complaint systems, and the transparency provided under the Freedom of Information Act are essential elements to ensure proper practice and safety.

…43. It is also vital that parents know who is teaching their children – and especially so when these are people from external unregulated organisations. It is self-evident that in a social media age children and young people can easily discover the activities of those who teach them. Where such people are engaged in promoting or portraying controversial and explicit sexual activities, which can readily be identified, this can give rise to serious safeguarding concerns…”.