DoL, Children and YP after AGNI - 9 December 2026

Aims

This one day course aims to update staff working with children, young people and those in transition with the latest case law and developments in relation to deprivation of liberty. The course will consider these developments and the impact on practice. It examines the Supreme Court ruling on deprivation of liberty and considers practical issues in its application for children and young people.

Learning Outcomes:

• Understand the ‘presumption of capacity’ from age 16; the overlap with parental responsibility until the age of 18 and how this differs to consent provided for children under 16

• Understand the supreme court ruling and it’s application to those aged under 18

• Identify when a deprivation of liberty may be occurring and how to make it lawful

Programme:

The day will include the following key topics:

• Latest News Supreme Court ruling 2026 (AGNI judgment)

• Case Law and understanding key concepts

• Article 5 and consequences

• Group discussion; is this DoL in children- 10, 17 and 18?

• Elements of Article 5-subjective, objective and State imputability

• Objective confinement:

• Deprivation of Liberty- European Court Onwards

• The Supreme Court Judgment

• The new threshold for DoL

• The restrictions:normality - purpose - compliance

• 'Valid consent' to deprivation of liberty 

• Application of judgement to children and Young People- the ‘nuanced test’

• Applying the Supreme Court Judgement to Under 18’s

• Universal Constraints

• Subjective element-Whose decisions count?

• Consent aged under 16 and the role of parents

• Consent aged 16-17 years and the role of parents

• The MCA 2005 and 16-17 year olds

• MCA and children case law

• Case law:

• Children aged 15

• Young People Aged 16 and17 years

• Children subject to ICO and Care Orders

• Deprivation of Liberty-how to make it lawful

• 18 plus care home or hospital

• 18 plus not in a care home or hospital

• 16-17 in any placement

• Under 16 in any placement

The course will be delivered by Dawn Revell

Dawn is a qualified Social Worker having obtained her professional status over 18 years ago. She continues to practice as an Approved Mental Health Professional (AMHP) under the Mental Health Act 1983.She is a joint trained investigator for safeguarding adults and presently has responsibility for managing and advising on complex safeguarding adult cases.  Dawn presently manages a generic, county wide social services emergency duty team. She has worked as an associate trainer for over 4 years and has designed, facilitated and delivered training on risk assessment, mental health, mental capacity and safeguarding adults.

All Event bookings must be made online with payment made in full by credit / debit card.  We do not send invoices/use Purchase Order numbers for Event bookings for NHS delegates  (this policy does not affect our commissioned bookings)

Course access details will be emailed direct to delegate(s) upon completion of your booking.  

Includes all course materials and a certificate. If you have any queries, please do not hesitate to email events@edgetraining.org.uk  or call 07341 277487.