Mustafa (a child), Re [2026] EWHC 2159 (Fam)

This judgment was delivered in private. The judge has given leave for this anonymised version of the judgment to be published on condition that (irrespective of what is contained in the judgment) in any published version of the judgment the anonymity of the children and members of their family must be strictly preserved. All persons, including representatives of the media, must ensure that this condition is strictly complied with. Failure to do so will be a contempt of court.[2026] EWHC 2159 (Fam)
IN THE HIGH COURT OF JUSTICE
FAMILY DIVISION
NATIONAL DEPRIVATION OF LIBERTY LIST
Venue Royal Court of Justice, Strand, LondonDate 12 th August 2026
WC2A 2LL
Case No FD26C40713Mr Recorder Adrian Jack(sitting as a High Court Judge)IN THE MATTER OF MUSTAFA (A CHILD), BORN 2010AND IN THE MATTER OF THE INHERENT JURISDICTION OF THE HIGH COURT AND SECTION 100(3) AND (4) OF THE CHILDREN ACT 1989LONDON BOROUGH OF BRENTApplicantMUSTAFA’S MOTHERRespondentMUSTAFA’S FATHERRespondentMUSTAFA (acting through his GUARDIAN)RespondentLondon Borough of Brent represented by Jake Barras, solicitorThe first respondent mother appeared in person assisted by her daughter for in person for The second respondent father did not appear and was not representedThe Guardian represented by Sandra Villani, solicitorHearing: 5 th August 2026Judgment date: 12 th August 2026
JudgmentThis judgment was handed down by the Judge remotely by circulation to the parties by email and release in anonymised form to The National Archives. The date and time for hand-down is deemed to be 12 noon on 12 th August 2026..............................Mr Recorder Adrian Jack
[1]In this matter concerns Mustafa, who will soon turn 16. The local authority seek to withdraw an application made on 4th June 2026 for an extension of a deprivation of liberties safeguarding order originally made by His Honour Judge Afzal CBE on 17th June 2025 and subsequently extended, most recently by Upper Tribunal Judge Keith on 11th June 2026. Unusually the Guardian opposes the withdrawal of the application for a DOLs order on the basis that the frequency with which physical restraint is used on Mustafa is inconsistent with his rights under Article 5 of the European Convention on Human Rights and so should be kept in place.[2]The case raises an issue as regards the application of the recent Supreme Court decision in A Reference by the Attorney General for Northern Ireland of a devolution issue under paragraph 34 of Schedule 10 to the Northern Ireland Act 1998 [2026] UKSC 16, [2026] 2 WLR 1087 (“AGNI”). Both advocates considered that it would be useful to have a written judgment giving guidance on the application of the new legal position to what is a not uncommon scenario. The facts[3]The facts are reasonably straightforward. Mustafa was born in 2010. He has Prader Willi syndrome and presents with developmental delay and additional learning needs. He moved to live at a specialist residential school in 2021. He remains there full-time, 52 weeks per annum. The specialist school is a regulated placement. The London Borough of Brent obtained a full care order in respect of Mustafa in 2022.[4]The DOLs orders provide:
“11. The confinement set out below which is in place for Mustafa is necessary, the least restrictive and is a proportionate response to the risk of harm which may arise: a) all doors leading to the main road to be kept locked and key to be kept out of Mustafa’s access to prevent Mustafa absconding; b) the kitchen door to be locked during night times; c) 1:1 care support at all times within home and in the community; d) the placement is permitted to provide 2:1 support as assessed by the placement to be necessary, to include when he is in the community; e) all kitchen tools and sharp tools to be kept out of reach and to be used only under supervision; f) care support for administration of medicines to safeguard his health; g) constant supervision to ensure the child's personal care needs are met in a safe manner; 12. There is reasonable cause to believe that, if the Inherent Jurisdiction is not exercised with respect to Mustafa, that he is likely to suffer significant harm. 13. In depriving Mustafa of his liberty, the local authority and staff members at [the School] are directed to use the minimum degree of force or restraint required. The use of such force and restraint is lawful and in Mustafa’s best interests provided always that the measures are: a) the least restrictive of the child’s rights and freedoms; b) proportionate to the anticipated harm; c) the least required to ensure the child’s safety and that of others; and d) respectful of the child’s dignity.” a) all doors leading to the main road to be kept locked and key to be kept out of Mustafa’s access to prevent Mustafa absconding; b) the kitchen door to be locked during night times; c) 1:1 care support at all times within home and in the community; d) the placement is permitted to provide 2:1 support as assessed by the placement to be necessary, to include when he is in the community; e) all kitchen tools and sharp tools to be kept out of reach and to be used only under supervision; f) care support for administration of medicines to safeguard his health; g) constant supervision to ensure the child's personal care needs are met in a safe manner; a) the least restrictive of the child’s rights and freedoms; b) proportionate to the anticipated harm; c) the least required to ensure the child’s safety and that of others; and d) respectful of the child’s dignity.”
[5]The Guardian does not disagree with the factual situation set out in the local authority’s position statement, which says this:
“In summary: (a) The Concrete Situation for Mustafa — he resides at a specialist residential school where he has lived continuously since late 2021. The placement is stable, settled and long-standing. It is his home and educational environment. He attends school, accesses community activities, maintains peer relationships, participates in leisure activities and enjoys regular family contact. The evidence demonstrates a young person who is integrated into his placement rather than isolated within it. (b) Mustafa has consistently described himself as happy living at the School. During the Local Authority's assessment undertaken following the Court's directions, Mustafa stated that he “likes living at [the School]”, spoke positively about staff and peers and identified a wide range of activities that he enjoys. He has never expressed a wish to leave the placement and has never asked to move elsewhere. (c) The effect of the arrangements on Mustafa is overwhelmingly positive. He has made significant progress in education, independent living skills, social development, emotional regulation and physical health. He enjoys a full programme of educational, recreational and community-based activities. He has meaningful family contact and returns to the placement after home visits without difficulty. (d) It is accepted that certain restrictions remain in place, including locked external doors, 1:1 supervision, monitoring around food, staff administration of medication and supervision in the community. However. the manner in which the arrangements are implemented is also relevant. Staff seek to provide a nurturing environment. The placement operates a restraint reduction plan, regularly reviews incidents and actively seeks to reduce restrictions where possible. Physical intervention is used only as a last resort where there is a risk of harm and staff increasingly utilise less restrictive strategies such as de-escalation, predictability and allowing Mustafa time and space to regulate. (e) Valid Consent— The Local Authority submits that this is the critical feature of the present case. The question is whether he possesses a sufficient level of awareness and understanding to know whether he is happy or unhappy with his living arrangements and to communicate that view. Mustafa clearly meets that threshold. (f) He is able to identify what he likes about the School, describe his relationships with staff and peers, discuss activities that he enjoys and articulate his future aspirations. He has expressed views regarding family contact and has specifically requested additional overnight stays with his family. (g) Importantly, Mustafa is not merely acquiescent. He routinely expresses preferences, disagrees with decisions, negotiates with adults and communicates dissatisfaction when he does not agree with something. (h) The significance of Mustafa's repeated and consistent statements that he likes living at the School cannot be understated. (i) The arrangements are protective and supportive in nature. They are directed towards enabling Mustafa to access education, maintain his health, participate safely in community activities, enjoy family relationships and develop independence skills. (j) Mustafa understands, in broad terms, why staff provide support. He understands that staff help him with medication, diet, healthcare, community activities and emotional regulation. He also understands why intervention may be required when there is a risk of harm. (k) There is no evidence that medication is being used in a manner that suppresses Mustafa's ability to express wishes and feelings. (l) Normality of Mustafa’s Circumstance — Mustafa is a looked after child with profound and enduring disabilities. His care arrangements must be assessed in the context of those disabilities and his very significant support needs. (m) The restrictions identified by the Local Authority are not arbitrary restrictions imposed upon an unwilling child. They are the practical measures required to enable Mustafa to live safely in a residential educational setting given his learning disability, limited awareness of danger, emotional dysregulation and history of absconding. (n) Viewed through the lens of Mustafa's own circumstances, the arrangements represent ordinary and necessary features of the specialist care package that he requires.”
[6]The Guardian, however, adds the following observations (omitting bundle references):
“13. At his LAC [looked after child] review in July 2026, Mustafa is described as being happy and settled in his placement at [the School] and making progress in some areas of his development. 14. Mustafa has an EHCP [education, health and care plan] and attends upper school, with 1:1 support. Mustafa is showing progress in reading, writing and numbers. Mustafa has been interacting well with his peers and is on a reward programme to ensure punctuality at school. 15. Mustafa’s independent living skills are noted to be improving, with Mustafa learning to prepare simple meals, keep his room tidy and complete some laundry tasks with support although at times can be resistant to the latter. 16. Mustafa is enjoying an active lifestyle and is following a bespoke high protein diet, such that he is maintaining a healthy weight (see LAC review minutes in February 2026). 17. However, Mustafa continues to require a high level of structure, routine, supervision and support at the School. 18. Mustafa continues to struggle with changes in routines, staff or around meals and family time, which can lead to anxiety and difficulties for Mustafa in regulating his emotions. At such times, Mustafa can struggle to process verbal information and can engage in destructive behaviours and aggression towards staff... Mustafa has been observed to engage in self-harming habits when distressed and can need time and space to regulate and reflect. 19. It is understood that there have been 48 recorded incidents since July 2025. Mustafa’s behaviour continues to necessitate the use of RPI on occasion, which he finds difficult. 20. However, the LA, in light of recent case law, do not see that the current arrangements result in restrictions or coercion but rather are there to protect Mustafa and that he accepts the restrictions. 21. The Guardian visited with Mustafa, along with his solicitor on [a day in] June 2026. Mustafa had returned to his accommodation from the school block. He was able to confirm that he recognized both from a visit the previous year. Some brief discussion occurred around a judge making decisions about his current living conditions, which Mustafa showed an interest in, and his having some knowledge of ‘police court’. It was clear that whilst Mustafa was not competent to instruct separately, he was clearly expressing his wishes and feelings. Part of the discussion was also had in the absence of the presence of members of staff. 22. Mustafa was asked a number of questions about how he felt about his circumstances and whilst he responded almost immediately in a positive manner, raising some concern as to whether he was processing information, it would appear that he was content with the current restrictions. Given that those instructed and the Guardian have worked with Mustafa for some time, albeit sporadically, we are aware that he does have the capacity to express what he does not like. A further reassurance was feedback received from the IRO [Independent Reviewing Officer] who attended the recent LAC review and ‘In relation to restrictive physical intervention/restraint’, Mustafa was asked how he feels when staff need to hold him to stop him hurting others or himself. At this review, he said he felt ‘fine’ about it and appeared to understand that it happens to keep people safe. [I] reminded him that at the previous review he had said he did not like restraint.”
[7]The social worker’s report of May 2026 describes the use of physical restrain in this way:
“Mustafa becomes physically aggressive and starts displaying physical aggression and destruction of properties when he struggles to regulate his emotion. This increases risk of harm for himself and for staff. He continues to require physical restraints (two persons holding each of his arms) to keep him and others safe.”
The submissions[8]The local authority submits “that considering Mustafa's concrete situation as a whole, and applying the multifactorial test mandated by [AGNI], Mustafa is not deprived of his liberty.”[9]By contrast the Guardian submits as follows:
“23. The court is to have regard to the recent decision [in AGNI]. This case effectively aligns more closely with the interpretation of Article 5(1) of the Human Rights Convention. 24. ‘In that context the starting point must be to identify to what an individual is or is not consenting, and that inevitably requires consideration of the objective element, regarding the circumstances of the confinement’: [Supreme Court at para [52]]. Thus, the specific situation of the individual concerned, and the assessment is multifactorial, with account taken of a whole range of factors including the type, duration, effects and manner of implementation of the measure in question. 25. In short, the objective and subjective elements are at play, and regard should be given to whether an individual can validly consent to the restrictions. Here Mustafa appears content with his arrangements and was able to communicate this to a number of professionals, including during his recent LAC review and also during the visit with his Guardian and Solicitor. 26. The Guardian has given very careful thought to the restrictions to the DOL order originally sought by the LA, and whether valid consent could be gleaned from Mustafa, but overall, the Guardian agrees with the LA, that the majority of the restrictions do not amount to coercion and that Mustafa does consent to them and understands the reasons are to keep him safe. 27. …[H]aving regard to the frequency of the need for restraint the Guardian is mindful that… Mustafa, while he does not like these restrictions, appears to have accepted them as part of his overall care arrangement. However, it remains difficult to know whether this is compliance by Mustafa rather than valid consent. 28. The Guardian believes that the frequency of restraint represents a regular pattern of the use of physical intervention to manage Mustafa’s behaviour of approximately every 9-10 days. This regular pattern, combined with the increase in the duration and intensity of the incidents, may lean to a necessity to renew the DOL Order. 29. To this end the Guardian believes that there is a need for DOL restriction when reasonable restraint is required to keep Mustafa safe.”
[10]An argument presented in a similar case heard by me in the same week as the current case was that a child or young person can give valid consent to being deprived of their liberty, only if they are deemed Gillick competent: Re C (A Child) [2016] EWHC 3473 (Fam), [2017] 2 FLR 875, applying Gillick v West Norfolk and Wisbech Area Health Authority [1986] AC 112. Further, it was submitted that the apparent consent given by a child or young person is likely to be insecure, not of an enduring nature and likely to be revised and retracted. A local authority should therefore apply for authorisation even if a child is giving their consent. The child's consent should form part of the court evaluation for whether authorisation to deprive the child of their liberty should be granted: Re T (A Child) [2021] UKSC 35, [2022] AC 723. The law and my conclusions[11]Article 5(1) of the European Convention on Human Rights provides:
“Everyone has the right to liberty and security of person. No one shall be deprived of his liberty save in the following cases and in accordance with a procedure prescribed by law: (a) the lawful detention of a person after conviction by a competent court; (b) the lawful arrest or detention of a person for non-compliance with the lawful order of a court or in order to secure the fulfilment of any obligation prescribed by law; (c) the lawful arrest or detention of a person effected for the purpose of bringing him before the competent legal authority on reasonable suspicion of having committed an offence or when it is reasonably considered necessary to prevent his committing an offence or fleeing after having done so; (d) the detention of a minor by lawful order for the purpose of educational supervision or his lawful detention for the purpose of bringing him before the competent legal authority; (e) the lawful detention of persons for the prevention of the spreading of infectious diseases, of persons of unsound mind, alcoholics or drug addicts or vagrants; (f) the lawful arrest or detention of a person to prevent his effecting an unauthorised entry into the country or of a person against whom action is being taken with a view to deportation or extradition.” (a) the lawful detention of a person after conviction by a competent court; (b) the lawful arrest or detention of a person for non-compliance with the lawful order of a court or in order to secure the fulfilment of any obligation prescribed by law; (c) the lawful arrest or detention of a person effected for the purpose of bringing him before the competent legal authority on reasonable suspicion of having committed an offence or when it is reasonably considered necessary to prevent his committing an offence or fleeing after having done so; (d) the detention of a minor by lawful order for the purpose of educational supervision or his lawful detention for the purpose of bringing him before the competent legal authority; (e) the lawful detention of persons for the prevention of the spreading of infectious diseases, of persons of unsound mind, alcoholics or drug addicts or vagrants; (f) the lawful arrest or detention of a person to prevent his effecting an unauthorised entry into the country or of a person against whom action is being taken with a view to deportation or extradition.”
[12]In determining whether there is a deprivation of liberty, the Supreme Court in AGNI summarised the relevant principles as follows at [53]:
“(i) The starting point in assessing whether someone has been deprived of liberty within the meaning of article 5 is the specific situation of the individual concerned, and the assessment is multifactorial, with account taken of a whole range of factors including the type, duration, effects and manner of implementation of the measure in question… The judgments of the European court show that no single factor is determinative. (ii) In addition to the objective element of confinement in a restricted space for a significant period, an individual will only be considered to be deprived of liberty if, as an additional subjective element, they have not validly consented to the confinement in question... Valid consent is therefore a powerful factor in the assessment. It is an autonomous concept and not to be equated with the concepts of consent for the purpose of waiver of rights under the Convention or of legal capacity in domestic law. The fact that an individual lacks legal capacity to decide on their living and care arrangements does not necessarily mean that they are de facto unable to understand and consent to those arrangements in a manner that prevents those arrangements from becoming a deprivation of liberty... On the contrary, an individual without legal capacity under domestic law, but who is conscious of their environment and has a basic understanding of their living circumstances so that they can express their view about their situation, who manifests their acceptance of the situation they are in, should have their opinion respected when an assessment is made of whether they are deprived of liberty under article 5. (iii) Although the objective and subjective elements of deprivation of liberty are often considered sequentially by the European court in its assessment of an applicant’s specific situation, there is an overlap. The requirement to take account of the ‘type’ and ‘effects and manner of implementation’ of the measure in question means that the assessment of the objective element can take account of the specific context and circumstances of restrictive measures that are different from the paradigm of confinement in a cell. (iv) The approach of the European court means that the effect of restrictions on an individual, including their compliance and the lack of objection if they are capable of objecting or giving tacit agreement, is relevant in assessing the objective element of confinement. The relative normality of the placement is also a relevant factor in this assessment. Similarly, in situations that are far from the paradigm of confinement in a cell, the purpose for which a measure has been taken is a factor to be considered. (v) The European court has recognised that the process of assessing whether there has been a deprivation of liberty is no easy task in some contexts and may give rise to difficulties, especially in borderline or marginal cases. Equally, it may sometimes be difficult to ascertain the true feelings or preferences of vulnerable individuals who do not have mental capacity to decide on their living arrangements. The approach should be practical and realistic. Where there is serious doubt, no inference of valid consent should be drawn.” 38. In making that determination, the Supreme Court applied the House of Lords’ 1966 Practice Statement (Judicial Precedent) [1966] 1 WLR 1234 to overrule the Supreme Court’s earlier decision in Surrey County Council v P; Cheshire West and Chester Council v P [2014] UKSC 19, [2014] AC 896, which held that “lack of mental capacity of an individual to consent to their care arrangements equates to lack of ‘valid consent’… In other words, an individual without such mental capacity is treated as unable to give valid consent to confinement.”
See AGNI at [12]. Instead, the degree of understanding was part of the multifactorial assessment of whether there is a deprivation of liberty. 39. This overruling of Cheshire West is in my judgment the answer to submission (made in my other case) that consent can only be given by a Gillick competent child. A child who is not Gillick competent may nonetheless have sufficient understanding for their views to be relevant as to whether they consent to aspects of deprivation of their liberty. 40. This, however, still leaves the issue as to whether Mustafa’s apparent consent is, as the Guardian submits, “compliance by Mustafa rather than valid consent” and whether his apparent consent “is likely to be insecure, not of an enduring nature and likely to be revised and retracted.” The Guardian is in my judgment right to point out that Mustafa may seek to withdraw any consent he has given, if he does not like particular restraints placed on him. Moreover in principle he can do this at any time, even (or indeed especially) whilst physical restraint is being used on him. This observation, however, overlooks the fact that in some cases schools are entitled to use physical restraint on children regardless of the child’s wishes. 41. The power physically to restrain children in schools has recently been considered by the Court of Appeal in FXS (through his father and litigation friend JLM) v Mulberry Bush Organisation Ltd [2026] EWCA Civ 415, [2026] 3 WLR 147. Popplewell LJ, giving the judgment of the Court, noted at [43]: “The right of teachers to use force against a pupil, or to detain a pupil, where there were reasonable grounds for believing that doing so was necessary for the welfare of the child or the welfare of the other children, was established in the nineteenth century in cases which based the right on teachers being in loco parentis. A parent could lawfully use such force or detention, and so, therefore, could teachers. The promotion of the welfare of the other children made it lawful to use force or detention where reasonable for the maintenance of good order and discipline in the school, because attending to those pupils’ welfare involved conferring the benefit of education. See, for example, Fitzgerald v Northcote (1865) 4 F & F 656, Hutt v Governors of Haileybury College (1888) 4 TLR 623, Price v Wilkins (1888) 58 LT 680, and Cleary v Booth [1893] 1 QB 465. These cases did not draw a distinction in this context between the use of physical force on the one hand and detention on the other, treating each equally as a form of punishment or coercion (see e.g. Hutt at p 624, and Mansell v Grifffin [1908] 1 KB 160 in which at pp 166-167 Phillimore J equated the principles to be applied in cases of deprivation of liberty to those applicable to the use of force).” 42. He noted at [38] that these common law powers of schools were given statutory effect in section 93 the Education and Inspections Act 2006. Section 93(1) and (5) of the 2006 Act provides: “(1) A person to whom this section applies may use such force as is reasonable in the circumstances for the purpose of preventing a pupil from doing (or continuing to do) any of the following, namely– (a) committing any offence, (b) causing personal injury to, or damage to the property of, any person (including the pupil himself), or (c) prejudicing the maintenance of good order and discipline at the school or among any pupils receiving education at the school, whether during a teaching session or otherwise. (5) The powers conferred by subsection (1) are in addition to any powers exercisable apart from this section and are not to be construed as restricting what may lawfully be done apart from this section.” (a) committing any offence, (b) causing personal injury to, or damage to the property of, any person (including the pupil himself), or (c) prejudicing the maintenance of good order and discipline at the school or among any pupils receiving education at the school, whether during a teaching session or otherwise.[13]In other words, if Mustafa withdraws his consent, the school has nonetheless the potential to restrain him under their common law powers. In general there will in my judgment be no breach of Article 5(1), if the school is properly using its common law powers of restraint.[14]When I stand back at look at all the factors relevant to the assessment as to whether there is a deprivation of liberty, in my judgment there is no deprivation of liberty. Mustafa is, as the Guardian sets out at length, generally happy in his placement. Where the school uses physical restraint, it either has Mustafa’s consent or it is entitled to use restraint under its common law powers. Either way, there is no deprivation of liberty such as to give rise to a violation of Article 5(1). An extension of the DOLs order is therefore neither necessary nor proportionate and I refuse to grant one. A procedural issue[15]A point which was not argued before me is the extent to which the Court can properly accede to the Guardian’s submission that the DOLs order should be extended, notwithstanding that the local authority, which is the applicant, does not wish the order to be extended. Normally an applicant can decide whether to proceed with its application or not.[16]In useful submissions, made after the circulation of this draft judgment, Mr Barras, solicitor for the local authority, said: “In relation to the court’s ability to invoke its inherent jurisdiction of its own motion, the matter appears to have been considered by the Supreme Court in Re NY (A Child) [2019] UKSC 49, [2020] AC 665. Lord Wilson stated: ‘Section 10(1)(b) of the [Children Act 1989] provides that a specific issue order can be made even though no application for it has been made; and there is no reason to doubt that an order under the inherent jurisdiction, the flexibility of which is a key feature of it, can also be made of the court’s own motion.’ However, the point does not appear to have been fully argued before the Supreme Court, this being the only reference to the issue and the observation may be regarded as obiter. It also appears to depart from earlier authorities, in particular Re AW (Adoption Application) [1993] 1 FLR 62 (Bracewell J). Although that decision is now relatively old, the issue appears to have been directly argued in a way that it was not in NY. It seems to me that there is a significant distinction between Parliament expressly conferring a power on the court to act of its own motion, as in s.10(1)(b) of the Children Act 1989, and the exercise of the court’s inherent jurisdiction, which, whilst preserved by the Act, is not accompanied by any equivalent statutory power to proceed without an application. However, I am not sure the issue in fact arises on the present facts. The local authority issued its application in the High Court and sought orders under the inherent jurisdiction. Even if those orders are no longer pursued, the proceedings remain before the High Court unless and until permission to withdraw the application is granted by the court pursuant to FPR 29.4. In those circumstances, the court’s inherent jurisdiction is already engaged. The position would, however, be different if the court were dealing solely with an application under the Children Act 1989. In that situation, I would suggest that the inherent jurisdiction would not be available in the absence of a properly constituted application invoking it.” ‘Section 10(1)(b) of the [Children Act 1989] provides that a specific issue order can be made even though no application for it has been made; and there is no reason to doubt that an order under the inherent jurisdiction, the flexibility of which is a key feature of it, can also be made of the court’s own motion.’[17]These are cogent submissions. Ms Villani, for the Guardian, preferred to reserve her submissions on this whilst the Guardian considered whether to apply for permission to appeal. However, whether the Court can exercise its inherent jurisdiction to make a DOLs order of its own motion must await determination when it is relevant.[18]In any event, the Guardian would not necessarily be without a remedy in a case where the local authority should be making an application for a DOLs order but decides not to. There is authority that it is not open to the Guardian to seek legal aid to act as the child’s litigation friend under CPR 21.2: Re SW and TW (Children: Human Rights Claim: Procedure) [2017] EWHC 450 (Fam), [2017] 1 WLR 3451, [2017] 2 FLR 1609 at [3]. The Guardian could nonetheless invite the Official Solicitor or another interested person, such as a parent, acting as the child’s litigation friend, to seek declaratory relief in the County Court (or possibly in an appropriate case the King’s Bench Division of the High Court). The declaration would be to the effect that the local authority was depriving the child of their liberty and that such deprivation would be unlawful unless and until the local authority obtains a DOLs order. Seeking a declaration would seem to be more appropriate than seeking an injunction, because the Guardian and the Official Solicitor or other litigation friend in this scenario would be actively wanting the local authority to use physical restraints on the child. The incentive for the local authority to seek a DOLs order would be the potential liability for damages for trespass to the child’s person, either for battery or for false imprisonment, if it did not do so.