Section 91(14) orders

In re S; In re E (permission to seek relief) CA TLR 13 September

When making an order under s91(14) of the Children Act 1989 prohibiting the making of any application without the prior permission of the court, it was not permissible for the court to impose conditions on the order restricting, or otherwise identifying, the circumstances in which an application for permission could be made. While it may well be appropriate for the court to impose a particular course of treatment on a party as a condition of making a contact order under s8 of the Act, it was impermissible to impose conditions on a s91(14) order, and, in particular, impermissible to require that a party undergo treatment as a precondition of making an application for permission to apply.