Acknowledgements
I would like to thank Nicolette Priaulx for her helpful comments on an earlier draft of this case comment.
Notes
1. This legislative reform was not retrospective. Therefore, even if Mr B was named as D's father on her birth certificate (which is not discussed in the case), he still has to take formal action in order to obtain parental responsibility.
2. Note that the ability to consent or object to an adoption was another significant ‘right’ considered by Black J (paras 21 and 94). This issue will be addressed in the discussion section.