onable 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 not automatically ‘appropriate’ for the agency to seek to make contact with the father solely in order to obtain background information. 2.45. If the father's identity cannot be established, the agency should seek legal advice. Each individual case will need to be considered and legal advice sought. One option would be to seek a direction from the court on whether it is lawful to place the child for adoption without consulting the father. Another option, available only to local authorities, is to apply for a placement order where the local authority considers that the requirements for section 31of the 1989 Act are met (conditions for making a care order threshold criteria). The latter approach has the merit of enabling the court to consider the circumstances of the case and reach a decision on whether the child should be placed for adoption. Where a VAA is approached in such a case, where there may be grounds for an application for a placement order, it should notify the local authority. If the local authority considers that the child should be placed for adoption, (and the section 31 requirements are met) it should apply for a placement order. 2.46. If the agency is working with a father who does not have parental responsibility it will be important to ensure that he is aware of his rights to apply for parental responsibility and/or a residence or contact order, and understands the importance of taking action without delay if he wishes to make any application. He should be encouraged to seek legal advice if he is in any doubt about his position. 2.47. Where the mother gives consent to placement for adoption, or advance cons