Care proceedings

A real possibility that a parent had harmed a child in the past was not, by itself, sufficient to establish the likelihood that that parent would cause harm to another child in the future. The findings of harm caused in the past might be relied on only to the extent that they might be relevant to the issue the court had to decide. A prediction of future harm based on what had happened in the past would only be justified if one could link what had happened in the past directly and unequivocally with the person and the new family unit in whose care the subsequent child was living or would live. Where the person who harmed a child could not be identified, the threshold could not be met in relation to another child solely on the basis that a possible perpetrator of the harm was involved in the care of that child unless all possible