“We are satisfied that the respondent has failed to take into account the Residence Order despite it forming part of the respondent’s bundle, and on the basis of those limited findings the following facts emerge:- (i) The appellant’s children have a right to reside here under the Residence Order from which flow two legal consequences that enable us to answer the question does the appellant fall into exception 1 of Section 33 of the 2007 Act or not? First it is clear that the Secretary of State has not taken into account a highly relevant and legal factor, that is the fact of the order, because that prevents the panel or the Secretary of State from properly taking into account the new approach of the House of Lords in Beoku-Betts[2008] UKHL 39 - which specifies that it is not just the appellant’s family life that needs to be taken into consideration, but that of the family members too, because the Order bears on the rights of some of them and because in light of that approach in Beoku-Bettsthe Order bears on the appellant’s rights as a mother. Therefore the first of these legal consequences is that the respondent has not taken into account this factor despite the guidance given to criminal case work by the respondent, a copy of which was handed up by Ms McAllister at the hearing and which records:- “A Residence Order made by a Family Court for a minor determines where they will live, and with whom. When an adult is granted a child’s Residence Order they automatically get parental responsibility for that child if they did not already have it. Parental responsibility obtained through a residence order will continue until the order expires. A Residence Order usually lasts until the child is 16 years of age unless the circumstances of the case are exceptional and the court decides the order should continue for longer. A Residence Order prevents any child who is the subject of the order being removed from the UK (for more than one month) without the written agreement of everyone with parental responsibility or an order of the court. If you are considering the removal or deportation of a child who is subject to a Residence Order you must discuss the case with a senior case worker and the Officers of Children’s Champion (OCC) to find out what action is appropriate on a case by cases basis. You cannot remove a child without the conditions of residency being satisfied or without a Court Order.”
“On all the evidence before us we conclude that it is disproportionate now to remove this appellant because the consequence of the Secretary of State’s decision is to separate the family members who see themselves as a family unit. We conclude that the appellant has established that she falls within the exception set out in Section 33(1) of the 2007 Act and therefore we allow the appeal.”
“On18 April 2012 . with the full support of social services, they were also made the subject of a residence order in favour of their father. The residence order automatically gave AFG parental responsibility for the three children. The court order stipulates that unless it was revoked or the children were 16, they could not be removed from the jurisdiction for more than one month without the consent of the father or the leave of the court.”
“Even if we are wrong, and there was a material error of law in the Panel’s approach, leading to the setting aside of the Determination under appeal this is plainly a case in which it would be appropriate for the Upper Tribunal to consider the matter on the evidence before it instead of remitting it to the First-Tier Tribunal. After taking into account all the relevant factors we would have reached exactly the same decision as the Panel did, particularly in the light of the fact that the related appeals have been allowed and the Secretary of State has not sought to challenge the Determination of First Tier Tribunal Judge Shamash. Whatever the position may have been at the time of the Panel’s Determination, it is undeniable that GHA’s partner and the children now have the right to remain in the UK and therefore there can be no question of the entire family unit being removed to Ghana. That being so, it would not be in the bests interests of the children to be deprived of contact with and the support of a loving mother, especially as there is no danger that she would pose any threat to their wellbeing and there is no significant risk of her reoffending”
“Although perhaps it might have been better had they given some explanation of why they were not considering whether the Immigration Rules applied, the Panel were entitled to go straight to the second stage of the two-stage process adverted to in MF (Nigeria) given that it was obvious that GHA did not meet the requirements of Rule 399 or 399A. In considering exceptional circumstances, the Panel did properly evaluate all the relevant factors in assessing whether the deportation of GHA would be a disproportionate interference with her rights and those of her partner and children underArticle 8 ECHR , and correctly reached the conclusion that it would. This is an even stronger case on its facts than Ogundimu. Even if we are wrong and there was a material error of law, the application of the appropriate legal tests to the facts of this case inexorably leads to exactly the same result. We therefore dismiss the Secretary of State’s appeal.”
“any lawful deportation order affecting a ward … would override any existing express order of the judge in the wardship proceedings that the infant was not to depart from the jurisdiction.”
“exactly the same fundamental principles apply whether the court is exercising its private law powers underPart II of the Children Act 1989 , its public law powers underPart IV of the Children Act 1989 , the wardship jurisdiction, or its inherent jurisdiction in relation to children recognised and to an extent regulated bys 100 of the Children Act 1989 . Proceedings under theAdoption Act 1976 apart, whatever jurisdiction he may be exercising a judge of the Family Division can no more than a judge of the county court or a family proceedings court make an order which has the effect of depriving the Secretary of State of his power to remove a child or any other party to the proceedings.”
“33 … A judge of the Family Division cannot in the exercise of his family jurisdiction grant an injunction to restrain the Secretary of State removing from the jurisdiction a child who is subject to immigration control – even if the child is a ward of court. The wardship judge cannot restrain the exercise by the Secretary of State for the Home Department of his power to remove or deport a child who is subject to immigration control … 34 This does not mean that the family court cannot make a residence order in respect of a child who is subject to immigration control or cannot make such a child a ward of court. Nor does it mean that the family court cannot make a care order in respect of such a child. What it does mean, however, and this is the important point, is that neither the existence of a care order, nor the existence of a residence order, nor even the fact that the child is a ward of court, can limit or confine the exercise by the Secretary of State of his powers in relation to a child who is subject to immigration control.”