Parental conflict, even if primarily generated by one parent, may constitute a sufficient basis for a care and protection declaration under s 30 of the Child Welfare Act 1947 (WA) where the conflict is detrimental to the children's welfare. Out-of-court statements of children admitted under s 30(3)(a) must be considered with great care, but the court is entitled to place particular emphasis on the most recent statement of a child expressing views about their future. The civil standard of proof applies to care and protection applications, but the court must be satisfied to a relatively high degree of the facts upon which the declaration is grounded.
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