LIACOS, J.
On September 14, 1981, a judge of the Probate and Family Court Department entered a decree allowing the petition of the Department of Social Services (department) to dispense with the need for parental consent for the adoption of a minor child. See G.L.c. 210, § 3. The father appealed this decree to the Appeals Court. On the motion of the department, the Appeals Court remanded the case to the Probate Court for further findings of fact. See Santosky...
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