In care proceedings the judge had been entitled to conclude that a father had sexually interfered with his four-year-old daughter based on a combination of evidence obtained from the daughter, although it had been obtained in breach of police interview guidelines, and other independent evidence. The only evidence to support an allegation that the mother was aware her daughter was being abused was the flawed interview with the daughter and the judge should not have relied on that alone to make a finding against the mother.

[2006] EWCA Civ 773