Prohibiting further applications

C (a child) [2009] EWCA Civ 674; SJ 8 December p30

Having dismissed the mother’s application for supervised contact, the judge made an order under s91(14) of the Children Act 1989 preventing the mother from making any applications regarding the child for a period of five years without permission of the court. The Court of Appeal set aside the order saying it was made all too casually and disregarded clear authority from the Court of Appeal. Wall LJ provided a list of all the factors to which practitioners should have regard. He emphasised they do not address the merits of s91(14) orders which are exceptional orders to make and the courts will be guided by the jurisprudence.