Harm as defined by the Children’s Act (as amended)

Reported cases on Harm

Section 31(9) of the Children Act 1989, as amended by the Adoption and Children Act 2002, defines harm as:
“Ill-treatment or impairment of health or development, including, for example, impairment suffered from seeing or hearing the ill-treatment of another.” ”

Based on my comprehensive research, I can now provide you with detailed reported cases interpreting section 31(9) of the Children Act 1989 and the definition of harm in the jurisdiction of England and Wales.

Reported Cases on Section 31(9) Children Act 1989: The Definition of Harm

Section 31(9) of the Children Act 1989, as amended by section 120 of the Adoption and Children Act 2002, provides the statutory definition of harm:

“Harm” means ill-treatment or the impairment of health or development including, for example, impairment suffered from seeing or hearing the ill-treatment of another.^[1][2][3][4]

The following reported cases have interpreted and applied this definition across the courts of England and Wales.

Leading House of Lords and Supreme Court Cases

Re H (Minors) (Sexual Abuse: Standard of Proof) AC 563

This House of Lords decision is the foundational authority on the threshold criteria under section 31(2) and the meaning of “likely to suffer significant harm”.^[5][6][7]

Facts: The eldest of four sisters alleged sexual abuse by her stepfather. He was acquitted at criminal trial. The local authority sought care orders for the three younger sisters on the basis that they were “likely to suffer significant harm.”

Held: The House of Lords dismissed the appeal. Lord Nicholls held that the threshold criterion requires the court to base its finding of “likely to suffer significant harm” on proved facts, not mere suspicion or unproven allegations. The threshold cannot be met on the basis of possibility alone – there must be evidential facts, established on the balance of probabilities, from which a real likelihood of future harm can be inferred.^[7][8][5]

Key principle on harm: The court confirmed that “harm” under section 31(9) encompasses ill-treatment or impairment of health or development, and that “development” includes emotional development. The majority held that “likely” means a real possibility of significant harm, not that harm is more probable than not.^[6][5]

Lancashire County Council v B 2 AC 147; UKHL 16

This House of Lords authority addresses the meaning of harm being “attributable to the care given to the child” under section 31(2)(b).^[9][10][11]

Facts: A child (A) sustained serious non-accidental head injuries caused by violent shaking on at least two occasions. The child had spent time with both parents and a childminder. The court was unable to determine which carer was responsible for the injuries.

Held: The appeal was dismissed. Lord Nicholls held that where there is a “pool of possible perpetrators”, the threshold under section 31(2)(b) can be satisfied even when it is uncertain which carer caused the harm. The phrase “the care given to the child” includes care given by any of the carers where care is shared.^[10][11][9]

Key principle on harm: The injuries constituted “significant harm” under section 31(9). The House of Lords confirmed that non-accidental physical injuries amount to ill-treatment causing impairment of health and development.^[11][9]

Re B (Children) (Care Proceedings: Standard of Proof) UKHL 35

This House of Lords decision clarified the standard of proof required to establish harm and the facts upon which findings of significant harm may be based.^{[12][13][8][14][15]}

Facts: Care proceedings concerned two young children. Allegations of sexual abuse were made by an older half-sibling against the father. The judge could not reach a definitive conclusion and questioned whether a “real possibility” of harm would suffice for the threshold.

Held: Baroness Hale, giving the leading judgment, held:

“I would go further and announce loud and clear that the standard of proof in finding the facts necessary to establish the threshold under section 31(2) or the welfare considerations in section 1 of the 1989 Act is the simple balance of probabilities, neither more nor less. Neither the seriousness of the allegation nor the seriousness of the consequences should make any difference to the standard of proof to be applied in determining the facts.”^[13][12]

Key principle on harm: The court confirmed that “harm” under section 31(9) includes emotional or psychological development, and that the threshold requires proof to the civil standard.^[8][14][12]

In re S-B (Children) (Care Proceedings: Standard of Proof) UKSC 17

This Supreme Court decision applied the principles from Re B and Re H to cases involving an unidentified perpetrator.^{[16][17][18][19][20][21]}

Facts: A four-week-old baby was found with non-accidental bruising. At the fact-finding hearing, the judge could not identify which parent caused the harm but suggested a 40% likelihood the mother was responsible.

Held: Lady Hale, delivering the judgment of the Court, held that the cases were “littered with references to ‘finding of exculpation’ or ‘ruling out’ a particular person as responsible for the harm suffered. That was to set the bar far too high.” If the evidence is not such as to establish responsibility on the balance of probabilities, it should nevertheless establish whether there is a real possibility that a particular person was involved.^[17][18][19]

Key principle on harm: The Supreme Court confirmed the expansive definition of harm under section 31(9), noting that physical injuries such as bruising and fractures constitute ill-treatment causing impairment of health.^[19][21][16]

In the matter of J (Children) UKSC 9

This Supreme Court case addressed whether a child could be regarded as “likely to suffer” harm based on a possibility that a parent was responsible for past harm to another child.^[22][16]

Facts: Care proceedings were brought in respect of three children. The local authority argued threshold was met because the children’s carer (JJ) had been found to be a “possible perpetrator” of fatal injuries to her first child (T-L) in earlier proceedings.

Held: The Supreme Court held that a finding that a parent was a “possible perpetrator” of harm to another child cannot, without more, establish the threshold that the current children are “likely to suffer significant harm”.^[22][16]

Key principle on harm: The Court confirmed the definition of harm under section 31(9), emphasising that past harm to another child can inform, but not automatically satisfy, the likelihood of future harm to siblings.^[22]

In the matter of B (a child) UKSC 33

The Supreme Court considered the application of section 31 in a case involving prospective emotional and psychological harm.^{[23][24][25][26]}

Facts: A two-year-old child was made subject to a care order with a view to adoption. The parents had psychological and personality disorders. The child had not suffered actual harm but the judge found threshold crossed based on likely future harm.

Held: Lord Wilson confirmed that “harm” under section 31(9) means “ill-treatment or the impairment of health or development” and that “development” includes “emotional development.” The conduct giving rise to harm need not be intentional or deliberate – section 31(2)(b)(i) requires only that the harm be “attributable” to the care given.^[25]

Key principle on harm: A child can be found likely to suffer significant harm even where no actual harm has yet occurred, provided there are proved facts establishing a real possibility of future harm to emotional or psychological development.^[24][23][25]

Court of Appeal Authorities

Re L (Contact: Domestic Violence) 2 FLR 334; EWCA Civ 194

This Court of Appeal authority is the leading case on the impact of domestic violence on the definition of harm to children.^{[27][28][29][30][31]}

Facts: Four appeals concerning contact applications where fathers sought direct contact with their children, but there was a background of domestic violence between the parents.

Held: Dame Elizabeth Butler-Sloss P held that courts must recognise that children may suffer harm from witnessing domestic violence even where they are not direct victims. The court should consider the effect of the violence on the child and the residential parent.^[29][31][27]

Key principle on harm: This case was instrumental in establishing that children can suffer significant harm from exposure to domestic violence, which subsequently led to the amendment of section 31(9) by the Adoption and Children Act 2002.^[32][27][29]

Re M and R (Minors) (Expert Opinion: Evidence) 2 FLR 195; 4 All ER 239

This Court of Appeal decision addressed the meaning of harm in the context of allegations of sexual abuse and emotional harm.^{[33][34][35][36]}

Facts: Care proceedings were brought on the basis that four children had been sexually abused. The judge held he was not satisfied on the balance of probabilities that allegations of sexual abuse were proved, but found there was a “real possibility” such abuse occurred. He made interim care orders based on emotional abuse and neglect.

Held: Butler-Sloss LJ confirmed that it is not enough that an alleged abuser has “possibly” abused a child. A finding of likelihood of significant harm must be based on facts justifying that finding. However, the court could make findings of emotional harm and neglect where those were established on the evidence.^[34][35][33]

Key principle on harm: The Court of Appeal held that the test for “harm” or “likely to suffer harm” should be consistent across section 31 and section 1 of the Children Act 1989.^[33][34]

Re MA (Care Threshold) EWCA Civ 853

This Court of Appeal case addressed whether children were at risk of significant harm based on the treatment of another child in the household.^[37][38]

Facts: A child (A) living in the household had been subjected to “shocking and cruel treatment” by the parents. The issue was whether the threshold criteria were satisfied for three younger biological children who had not been directly harmed.

Held: The majority upheld the trial judge’s ruling that threshold was not satisfied for the biological children, despite the proven ill-treatment of child A. Wilson LJ dissented, stating he was “staggered” by the ruling.^[38][37]

Key principle on harm: The court considered the amended definition of harm under section 31(9), including “impairment suffered from seeing or hearing the ill-treatment of another.” The case illustrates that witnessing ill-treatment of another child can, but does not automatically, satisfy the threshold.^[37][38]

L-G (Children: Risk Assessment) EWCA Civ 60

This recent Court of Appeal authority provides important guidance on the assessment of significant harm in care proceedings.^[39][40]

Facts: Care proceedings concerning three children where findings had been made in previous proceedings that the mother had caused a skull fracture to one child, albeit without finding the injury was deliberately inflicted.

Held: The Court of Appeal emphasised the need for a structured assessment of what constitutes “significant harm” for threshold determinations, both by reference to the wording of section 31 and by the application of the law on a case-by-case basis.^[40][39]

Key principle on harm: The court confirmed that section 31(9) provides an “expansive definition” of harm that includes harm to the child not just from the treatment they receive but also from observing ill-treatment of others, such as family members.^[39][40]

Re T (Children: Risk Assessment) EWCA Civ 93

This companion case to L-G provided further guidance on the welfare assessment in care proceedings.^[40][39]

Facts: Care proceedings concerning children where risk of harm was at issue.

Held: The Court of Appeal reiterated that the Children Act 1989 provides a framework within which the court can assess whether a child has suffered or is likely to suffer “significant harm” for threshold purposes, and “harm” for welfare assessment purposes, referring to the definition pursuant to section 31(9).^[39][40]

Re S & H-S (Children) EWCA Civ 1282

This Court of Appeal case addressed emotional harm and the threshold criteria.^[41]

Facts: Care proceedings were initiated on the basis of allegations about physical harm by the father. The allegations fell away but assessments highlighted emotional harm and poor attachment to the mother.

Held: The Court of Appeal considered whether emotional harm, established during proceedings, could satisfy the threshold even where the original basis for proceedings (physical harm) was not proved.^[41]

Key principle on harm: The case confirms that emotional harm constitutes “impairment of development” under section 31(9) and can satisfy the threshold independently of physical harm.^[41]

The Statutory Amendment: Section 120 Adoption and Children Act 2002

The definition of harm in section 31(9) was clarified by section 120 of the Adoption and Children Act 2002 (implemented 31 January 2005) to make clear that harm includes:

“any impairment of the child’s health or development as a result of witnessing the ill-treatment of another person, such as domestic violence”^{[42][43][44][45]}

The Explanatory Notes to section 120 state:

“‘Ill-treatment’ is already defined in section 31(9) of the Children Act 1989. It is broader than physical violence and includes sexual abuse and forms of ill-treatment which are not physical. Any harm a child suffers because a parent is being harassed or intimidated is caught by the definition of ‘harm’. The amendment will apply to all proceedings where the court applies the ‘welfare checklist’ in section 1(3) of the Children Act 1989.”^[42]

Summary of Key Principles from Reported Cases

These authorities demonstrate the comprehensive judicial interpretation of the statutory definition of harm in England and Wales, encompassing physical, emotional, sexual abuse and neglect, as well as harm suffered from witnessing the ill-treatment of another person.

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