# Case (DOL of under 16s). Re RN (Deprivation of Liberty and Parental Consent) \[2022\] EWHC 2576 (Fam) **URL:** \ **Category:** MHLO updates\ **Created:** [27 February 2023 21:48 UTC](https://forum.mentalhealthlaw.co.uk/t/case-dol-of-under-16s-re-rn-deprivation-of-liberty-and-parental-consent-2022-ewhc-2576-fam/1494 "2023-02-27T21:48:33Z")\ **Posts on this page:** 1\ **Page:** 1
**Author:** ![MHLO](https://forum.mentalhealthlaw.co.uk/user_avatar/forum.mentalhealthlaw.co.uk/mhlo/32/24_2.png) [@MHLO](https://forum.mentalhealthlaw.co.uk/u/MHLO)\ **Post date:** [27 February 2023 21:48 UTC](https://forum.mentalhealthlaw.co.uk/t/case-dol-of-under-16s-re-rn-deprivation-of-liberty-and-parental-consent-2022-ewhc-2576-fam/1494/1 "2023-02-27T21:48:33Z")
— The local authority sought declarations under the inherent jurisdiction authorising the deprivation of liberty of a 12-year-old girl in her father's home. The Supreme Court in [Re D (A Child) [2019] UKSC 42](https://www.mentalhealthlaw.co.uk/Re_D_(A_Child)_(2019)_UKSC_42 "Re D (A Child) [2019] UKSC 42") had decided that parental consent cannot authorise DOL of 16-17 year olds. The High Court in this case concluded: "It follows from all that I have said that the restrictive care arrangements in place for RN are a proper and lawful exercise of parental responsibility. This amounts to a valid consent, with the consequence that the second limb of the established three stage test for what amounts to a deprivation of liberty is not met. In such circumstances, this Court need not make any High Court declaration authorising them. They are rendered lawful by the parental consent." * * * Full details available at: [https://www.mentalhealthlaw.co.uk/Re\_RN\_(Deprivation\_of\_Liberty\_and\_Parental\_Consent)\_(2022)\_EWHC\_2576\_(Fam)?id=270223-2136](https://www.mentalhealthlaw.co.uk/Re_RN_(Deprivation_of_Liberty_and_Parental_Consent)_(2022)_EWHC_2576_(Fam)?id=270223-2136)