Statement of opposition in child care proceedings failed to identify salient issues

Family law - applicant seeks by way of a notice of motion an order pursuant to O. 84, r. 22(5) of the Rules of the Superior Courts striking out the statement of opposition filed on behalf of the respondent dated 15th January, 2016, in circumstances where the respondent’s statement of opposition fails to say precisely each ground of opposition, giving particulars where appropriate, to identify the facts of the matters relied upon and to support the matters contended for and deal specifically with each fact or matter relied upon in the statement grounding the application - in October 2015 the applicant sought leave to apply for judicial review and leave to apply was granted - applicant seeks an order striking out the statement of opposition filed on behalf of respondent made in response to plaintiff's application for judicial review - statement sought order of prohibition or injunction restraining the respondent from proceeding with the investigation into complaints in respect of four children where it had been determined by social worker that the complaints were within the remit of the board of management of the school - applicant also sought relief restraining the respondent from proceeding with the investigation in relation to the complaints in circumstances where it is intimated that the parents of each child are prepared to have child interviewed by the respondents social worker - applicant also sought relief restraining the respondent from proceeding with an investigation into a complaint in circumstances where the respondent had determined that there were no child protection concerns - applicant is a teacher in a school about whom complaints were made to the board of management of the school in 2007 - these were investigated and the chairman of the board of management wrote to the father in March 2008 of the students made complaints, confirming that the matter had been dealt with - in January 2014 unbeknownst to the applicant, the social work team leader with the respondent wrote to the school principal stating that the respondents have recently received a number of referrals in relation to the applicant concerning this treatment of children during the working day - this team leader visited the principal who informed the applicant of the visit that day - several days later, the team leader wrote to the principal and confirmed that the four children gave what they deemed to be credible accounts of intimidation and emotional abuse - in April 2014 the team leader wrote to the applicant inviting him to meet her and proposed a date - a union representative wrote several days later stating that the applicant was anxious to cooperate and meet but required full information and documentation in advance of any meeting - the team leader replied the next day stating that she would not correspond with the union representative, only with the applicant directly - the applicant met with the board of management on 13 May 2014 to consider whether he should be put on administrative leave - he was subsequently informed that he would not be placed on administrative leave - in September 2014 solicitors for the applicant wrote to the respondent noting that the respondent had not afforded the applicant with an opportunity to know what was being alleged against him and to respond - the principal social worker wrote to the applicant in March 2015 but did not specify any allegations made against him - in June 2015, in response to a request from the applicant's solicitors, solicitors for the respondent replied stating that the principal social worker would step down from any further involvement - in September 2015 the legal office for the respondent, who was now acting for the respondent, wrote to solicitors with the applicant stating that they proposed to commence a fresh assessment of any outstanding allegations made against the applicant - affidavit of respondent did not contain information contained in correspondence - statement of opposition struck out in circumstances where it failed to state precisely each ground of opposition giving particulars where appropriate - new statement of opposition ordered.