Since HA (Iraq) in the Supreme Court, the "unduly harsh" question in deportation appeals has to be answered for the actual child in the actual family, without measuring them against some notional child who could be expected to cope. That sounds obvious. In practice it changed what evidence wins these appeals, because a generalised statement that separation harms children no longer does the work. The tribunal needs to know about this child.

What social work evidence adds

A social worker's job, done properly, is precisely the individual picture. What does this child's day actually look like, and where is the appellant in it? What does the school say, and the GP? How does this child respond when the parent leaves the room, and what has already happened to them in their short life that bears on what a permanent separation would do? Both scenarios the tribunal must consider, the child going and the child staying, need that treatment, separately, because they are different questions with different answers.

What it cannot do

A social work report cannot decide the appeal, and a report that argues the case instead of evidencing it will be read for exactly what it is. It cannot make findings about disputed events; that is the tribunal's job. And it cannot manufacture harshness where the evidence shows resilience. An expert who reports that a child would cope, where that is what the evidence shows, is doing the appellant a service in the only currency that matters, which is credibility.

Why the family court connection matters

Many deportation families have family court history: previous proceedings, social services involvement, assessments. That material cuts both ways and it will be known to the Home Office. An expert who works in the family courts can read that record fluently, put it to the family, and deal with it in the report before the presenting officer deals with it in cross-examination. The alternative, a report that ignores the record, has been publicly criticised by the Upper Tribunal, and the criticism followed the expert, not the solicitor.

The practical point

If you are running an Exception 2 case, commission the child evidence early, send everything, and instruct against the legal test. The difference between a report that recites the family's account and one that has tested it is usually the difference between "little weight" and evidence the determination quotes.

Frequently asked questions

What does "unduly harsh" mean in a deportation appeal?

It is the statutory test in section 117C of the Nationality, Immigration and Asylum Act 2002 for the effect of deportation on a qualifying partner or child. The Supreme Court has described the threshold as elevated: something severe or bleak, going beyond what any family would face when a parent is deported. Since HA (Iraq) in 2022, it must be assessed on the evidence about the actual child and partner in the case, not against a notional comparison.

Can a social work report conclude that deportation would be unduly harsh?

No, and a report that does so has overstepped. "Unduly harsh" is the Tribunal's finding, not the expert's. What a social work report properly does is evidence the severity and the consequences for the particular child or partner, in both scenarios, so the Tribunal can apply the label itself.

What are the two scenarios a report must address?

The family accompanying the person facing deportation, and the family remaining in the UK without them. The case law requires each to be assessed separately, because they are different questions with different answers for the same child.

What evidence about a child carries weight?

Individualised evidence: the child's daily life and where the parent sits in it, school and GP information, observation of the relationship, the child's own age-appropriate voice, and engagement with any family court history. Generalised statements that separation harms children carry no weight, and tribunals say so in published decisions.

Related guides

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