⟡ N244 Application Bundle – Strike Out or Vary Interim Care Orders ⟡
Filed: 22 September 2025 — precisely 08:00 hours
Reference: SWANK/N244/ICO/2025-09-21
Download PDF: 2025-09-21_N244_StrikeOutOrVaryICO_Bundle.pdf
Summary: Core bundle application to dismiss or vary Interim Care Orders dated 23 June 2025, with support and annexed evidence establishing disproven allegations, procedural abuse, and rights violations.
I. What Happened
• On 21 September 2025, the Applicant filed an N244 Application in the Central Family Court (Case ZC25C50281).
• Relief sought: strike out the proceedings as an abuse of process (FPR 4.4), or in the alternative, discharge the ICO and direct immediate reunification of the children.
• Grounds: false intoxication allegation disproven by NHS Resolution and oxygen evidence; procedural defects; welfare harm; breaches of Children Act 1989; violations of Equality Act 2010 and Articles 6 & 8 ECHR.
II. What the Document Establishes
• The ICO rests on a false foundation: a misread oxygen saturation chart at St Thomas’ Hospital, reframed as “intoxication.”
• Procedural lawlessness: coercive misuse of s.20, disregard for welfare checklist, children’s voices silenced.
• Welfare collapse: disrupted homeschooling, asthma instability, belongings withheld.
• Human rights infringed: separation disproportionate, discriminatory, and irrational.
III. Why SWANK Logged It
• To preserve the judicial record of retaliatory escalation: Audit Demand → Cease & Desist → PLO → EPO → ICO.
• To demonstrate that state safeguarding powers were weaponised not for welfare, but to deflect liability.
• To anchor dismissal in Bromley’s authority (consent must be real, voluntary, informed) and Amos’ doctrine (proportionality is non-negotiable).
IV. Applicable Standards & Violations
• Children Act 1989 – s.1, s.22 duties to promote upbringing within the family.
• FPR 4.4 – abuse of process justifies strike-out.
• Equality Act 2010 – breach of reasonable adjustments, indirect discrimination.
• ECHR Articles 6 & 8 – fair trial, family life.
• Case Law – Re B-S, Re C, Mabon, Johansen v Norway, Neulinger & Shuruk v Switzerland.
• Academic Anchors – Bromley’s Family Law; Amos, Human Rights Law.
V. SWANK’s Position
The ICO is not safeguarding — it is institutional retaliation draped in judicial costume.
We do not accept foundations built on falsity.
We reject coercion dressed as consent.
We document the retaliatory sequence until the Court itself cannot look away.
⟡ This Entry Has Been Formally Archived by SWANK London Ltd. ⟡
Every allegation disproven. Every procedural breach annotated. Because a false order deserves not variation but extinction.