Adoption — refusal to consent — Adoption Act 1955, ss 8 and 11 — Director General of Social Welfare v L [1990] NZFLR 125 — P v C [2001] NZFLR 193. An application to dispense with the father's consent to an adoption order sought by the biological mother and step-father was refused. The Court of Appeal case "L" was referred to as demonstrating the high threshold that must be reached before consent could be dispensed with. Although the father's parenting was "lethargic and substandard", it did not meet the threshold required by s 8 of the Act. In particular it could not be classified as a total failure to "exercise a normal duty in care of parenthood". Where consent is not dispensed with, and is withheld such as in this case, the Court may not grant the adoption order "no matter how meritorious" ("P v C"). Judgment Date: 5 September 2016. * * * Note: Names have been changed to comply with legal requirements * * *