A care order, allowing the non-consensual removal of a child from parental care, has exacting requirements. A court must find that the child is suffering, or likely to suffer, significant harm caused by the absence of reasonable care or control (Children Act 1989, s. 31 – all other statutory references are to this Act). The child’s welfare is paramount (s. 1), and the order must be human rights-compliant. Section 20, however, enables a local authority to accommodate a child without an order in certain circumstances, ostensibly with relevant parents’ cooperation. While there is in principle a clear distinction between these voluntary and compulsory forms of intervention, contained in Parts III and IV (see also Part V) respectively, there is evidence of “misuse and abuse of section 20” (Re A (A Child), Darlington Borough Council v M [2015] EWFC 11, [100]), whereby councils accommodate children under it in arguably dubious circumstances while avoiding safeguards flowing from the timely seeking of a care order. In Williams v Hackney London Borough Council (Coram Children's Legal Centre and others intervening) [2018] UKSC 37, [2018] 3 W.L.R 503, the Supreme Court was more tolerant of local authorities’ use of s. 20 than might have been expected, denying compensation to parents whose eight children had been accommodated under it.