In re J (Children) (Care Proceedings: Threshold Criteria) [2013] UKSC 9; [2013] WLR (D) 74
“A real possibility that a parent had harmed a child in the past was not, by itself, sufficient to establish that some other child that he or she now had care of was ‘likely to suffer significant harm’ within the meaning of section 31(2)(a) of the Children Act 1989 so as to meet the threshold for initiating care proceedings in respect of that other child.”
WLR Daily, 20th February 2013
Source: www.iclr.co.uk