Family proceedings

The Family Division granted the applicant’s applications for a declaration recognising her adoption of a child, N, in India, and for an adoption order in respect of N. The court held, among other things, that Re Valentine’s Settlement [1965] 2 All ER 226 remained good law and binding upon judges at first instance. Accordingly, recognition at common law of a foreign adoption, whether the question arose in a court or elsewhere, depended upon, and only upon, the four criteria identified in Re Valentine’s Settlement. Applying settled law, the court held that English law recognised N’s adoption by the applicant in India and that it was manifestly in N’s best interests, currently and throughout her life, that the adoption order be made.