High Court approves ICPO extension in SWE v Evans but emphasis need for expedited progress

Case Summary

In the case Social Work England v. Evans [2025] EWHC 188 (Admin), heard by Mrs. Justice Hill DBE at the High Court of Justice, Leeds District Registry, on January 30, 2025, Social Work England (SWE) sought an extension of the Interim Conditions of Practice Order (ICPO) imposed on Susan Okpani Evans, a social worker.

Background

Evans was employed by Haringey Council as a social worker in the Disabled Children’s team. Concerns about Evans’ professional conduct arose from her handling of Family A, where she failed to recognize and address risks posed by a known child sex offender (referred to as B) having contact with the children. Despite a High Court order, Evans’ actions were deemed inadequate, leading to disciplinary proceedings.

ICPO Details

The ICPO was initially imposed on April 8, 2021, allowing Evans to practice under specific conditions, including informing SWE of any employment and permitting SWE to liaise with her employers. The order had been reviewed 11 times, with each review concluding the necessity of the ICPO for public protection and maintaining confidence in the profession.

Legal Framework

The power to impose an ICPO on a social worker’s registration is granted under Paragraph 8(5) of Schedule 2 of the Social Workers Regulations 2018. The ICPO can last up to 18 months and can be extended by the High Court upon application by SWE. The High Court must ensure that the criteria for imposing the ICPO, including protection of the public and the practitioner’s best interests, are met.

Court’s Analysis and Decision

Mrs. Justice Hill considered several factors, including the gravity of the allegations against Evans, the risk of harm to service users, the delay in concluding the case, and potential prejudice to Evans. The allegations against Evans were serious, reflecting a fundamental lack of understanding of safeguarding principles, posing significant risks to the children in her care, and harming the profession’s reputation.

The delay in concluding the case was attributed to the extensive time required to obtain essential material from the Family Court. Despite Evans’ expressions of concern and frustration over the four-year duration of the proceedings, the court found that extending the ICPO for an additional seven months was necessary for public protection.

The court allowed SWE’s application to extend the ICPO until September 3, 2025, emphasizing the need for expedited progress in concluding the case. The extension was deemed necessary to safeguard the public and maintain confidence in the social work profession, with a caution that future extensions might not be granted.

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