R (on the application of A) v A Local Authority [2010] EWHC 848 (Admin), [2010] All ER (D) 49 (May)
R (on the application of D) v A Local Authority [2007] All ER (D) 110 (Mar) gave valuable guidance as to the types of matters that might be relevant in determining the nature of the placement of a child in those cases where the carer was the relative of the child.
The fact and nature of the relationship was relevant when evaluating the situation in accordance with that guidance; there might be some cases in which the fact that the person with whom the child was to live was a relative would make all the difference to the outcome. H (a child) (care: local authority), Re [2003] All ER (D) 250 (Nov) was to be read as meaning that where a placement did in fact take place with a relative under s 23(6) of the 1989 Act, the child was provided with accommodation by the authority.
Authorities who arranged for children to live with relatives could do so either under s 23(2) or 23(6) of the 1989
