K (Children) [2012] EWCA Civ 1549

The CA determined that the court has jurisdiction to make sequential s.37 directions and with them Sequential ICOs in certain appropriate circumstances but that in the instant case the court had on one occasion exceeded its jurisdiction where the LA had filed a comprehensive s.37 report and did not seek an ICO or to issue proceedings. However the parents’ wider appeal against the final orders made in 2012 was dismissed.