*Re M (A child) (Placement order: authority's dual planning approach)

Family proceedings – Orders in family proceedings. The local authority care plan in respect of a child had included an option for adoption and, if not achieved within six months, a dual track approach of pursuing adoption and long term fostering arrangements. The judge granted a placement order and the mother appealed. The Court of Appeal, Civil Division, held that it was not necessary for an authority to have a contingency in a care plan, although it was desirable and that an authority was not precluded from adopting a dual planning approach in an appropriate case. They also clarified that the phrase 'nothing else will do' was the conclusion of a proportionality evaluation after a process of deductive reasoning and not a new presumption or standard of proof.

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