X City Council v M (The Mother) & Ors

In care proceedings, the local authority bears the burden of proving each allegation on the balance of probabilities. The court must decide disputed allegations from evidence, while drawing logical inferences where justified. It must assess each allegation separately but consider the entire evidential canvas and avoid compartmentalisation. Expert evidence informs the court but does not determine the issue; medical opinion must be evaluated alongside factual evidence, including the parents’ accounts. A proposed alternative medical explanation cannot succeed merely because medical knowledge may develop: it requires evidential support. Where the medical and wider evidence establishes that excessive salt was administered to an infant, the court may find deliberate administration even without proof of motive.

The local authority sought findings that the mother had deliberately given excessive quantities of salt to C, one of three children, causing significant harm through recurrent hypernatremia. The mother denied poisoning C and suggested that omeprazole or another medical cause might explain the raised sodium levels. The father denied involvement, and the children were represented by a guardian.

The court heard evidence from treating clinicians and instructed experts in paediatric nephrology, endocrinology, neuroradiology, clinical genetics and paediatrics. The central issues were the cause of C’s abnormal sodium levels, whether the episodes were consistent with dehydration or salt poisoning, and whether the local authority had proved its allegation.

1. Finding. The court found, on the balance of probabilities, that the mother had given C excessive quantities of salt as pleaded in the local authority’s threshold. The clinical evidence overwhelmingly supported salt poisoning.
2. The local authority bore the burden of proof. The court applied the civil standard. An allegation either became an established fact if proved more probably than not, or was treated as not having occurred. The court was required to decide each allegation on evidence rather than speculation, while drawing logical inferences from accepted evidence.
3. The court considered the whole evidential canvas and avoided compartmentalising individual items. Expert evidence was advisory. Responsibility for findings remained with the judge, who had to evaluate medical opinion together with the factual evidence and the parents’ accounts.
4. The repeated sodium readings, the markedly elevated fractional sodium excretion, stable weight pattern, absence of convincing gastroenteritis or dehydration, normal kidney function and absence of a genetic explanation pointed to excessive salt administration. The evidence did not establish any link between omeprazole and the raised sodium levels. A possibility based only on developing medical knowledge or an unsupported alternative explanation could not displace the expert evidence.
5. The changes in sodium levels during the March and May hospital admissions supported the conclusion that salt had been administered during those periods. The absence of further illness after C moved from the parents’ care was additional supportive evidence.
6. Although no motive was established, motive was unnecessary. The mother was C’s primary carer and generally fed her. The family circumstances, her severe stress and limited support did not disprove the allegation. The court considered that administering salt in hospital would have been possible despite staff movements and the preparation of feeds by nurses.