Parent in special care proceedings entitled to recover costs despite receipt of legal aid

The High Court determined that a parent who participated as a respondent in special care proceedings is entitled to seek an order for her legal costs, even where she received legal aid. The court found that the parent’s involvement was necessary for the welfare of the child, who was subject to a special care order, and that her right to apply for costs should be adjudicated without regard to her legal aid status. The court rejected arguments that only the child or guardian ad litem should recover their costs, holding that the legal and constitutional rights of parents justify a costs award in suitable cases. The mother's conduct throughout was reasonable and beneficial to the court and her child, and so she was awarded her costs, to be determined in the usual way.