Parent and child – Adoption. Court of Session: In an appeal by the natural mother of a 7½-year old girl, whose foster parents were seeking to adopt her, the sheriff having dispensed with the mother's consent and granted the adoption order, the court held that at the point of deciding the threshold issue of whether the 'parental incapacity ground' applied, considerations under art 8 of the Human Rights Convention did not arise, so the sheriff could not be criticised for not having had regard to them at that stage, and in so far as the appellant might have been trying to argue a wider point the criticisms that were made should be rejected.