Declaration that child in need of care and protection — whether subsequent child should be subject to a declaration — whether determination under s 18B(2)(c) — Children, Young Persons and Their Families Act 1989, ss 14 and 18 — Ministry of Social Development v BK & MR [2016] NZFC 10716. The child was declared in need of care and protection under s 14(1)(a), (b) and (ba). In relation to the s 18 (subsequent child) order it was found that the mother's agreement in relation to the fact that there was no realistic prospect of return of her older children, retroactively satisfied the requirement in s 18B(2)(c) that a determination can be made subsequently to s 48 COCA order or a s 101 or 110 CYPF order. Judgment Date: 15 February 2015. * * * Note: Names have been changed to comply with legal requirements * * *