 made a respondent with an opportunity to be heard. 2.42. In the case of Re G the parents had never lived together and their relationship did not show de facto family ties and did not come within the concept of family life: the father had no right to respect for family life. It was therefore not necessary for him to be given notice or joined as a party to the proceedings. 2.43. Whether or not the father without parental responsibility enjoys a right to family life under Article 8 will depend on the facts of the case. As part of its counselling of the mother, the agency should explain its obligations under Article 8 towards a father without parental responsibility in relation to counselling and seeking his views. In Re C, the court emphasised the fact that the adoption agency cannot simply act on the information given by the mother; it must critically examine what she says and it will be a question of judgment as to whether this needs to be checked or corroborated. It is important that the agency make it clear to the mother that disclosure is a matter for the agency’s or court’s discretion and therefore that agency must be careful not to give any undertakings as to whether or not the father will need to be notified of adoption proceedings. 3 The case was heard under the 1976 Act and the Adoption Rules 1984. The Family Procedure Rules 2010 allows the court to direct that any person be made a respondent to proceedings. 43 2.44. The paramount consideration for the agency must be the child’s welfare. Where the agency considers that it is appropriate – i.e. that it is in the child's best interests - the agency must take all reasonable steps to trace and counsel the child's unmarried father, if his identity is known. In the case of Re C, the Court of Appeal held that it was no