Corinne Iten represented the second and third respondent children through their Children’s Guardian, in the Court of Appeal in T and F (Placement Orders: Child’s Permanence Reports) [2026] EWCA Civ 902.
The appeal raised an important procedural issue concerning applications for placement orders under section 21 of the Adoption and Children Act 2002. The parents argued that the local authority’s failure to serve the children’s permanence reports before the final hearing constituted a serious procedural irregularity requiring the placement orders to be set aside.
The Court of Appeal (Baker LJ, Falk LJ and Miles LJ) accepted that the failure to serve the reports amounted to a “serious procedural irregularity”. However, it unanimously dismissed the appeal, holding that the irregularity had not rendered the outcome unjust. The Court found that the substance of the permanence reports had been contained in other material before the court and available to the parties, such that the parents had suffered no material prejudice.
Corinne appeared on behalf of the Second and Third Respondents, represented through their Children’s Guardian, instructed by Dutton Gregory. The full judgment is here.
