AR (Whether restrictions amount to a deprivation of liberty), Re

Facts

AR is a 25-year-old man with a moderate to severe learning disability and autistic spectrum disorder who lived for most of his life with his parents, PR and QR. Since May 2025 he has lived in a supported living placement, initially by way of respite care and now on a more permanent footing. Salford City Council brought proceedings in the Court of Protection concerning his residence and care; AR was represented by his litigation friend, LF, and his parents appeared in person. The parents did not press for AR to return home to live, accepting that his needs are met at the placement, but sought contact at their home, overnight and without a member of staff present, and complained that the local authority undervalued their place in their son's life. No fact-finding hearing had been held on the allegations concerning the parents' earlier care of AR. At an earlier hearing the judge directed the parents to respond to the psychological report of Dr Radcliffe and to file a statement. The court was also asked to decide, following the Supreme Court's decision in the Northern Ireland reference, whether the restrictions in AR's care plan amounted to a deprivation of liberty, and whether a periodic review by the court should be ordered.