Re L ( A Child) [2013] EWCA Civ 179 (13 March 2013)

The CA considered the circumstances in which it was permissible for a judge to make an interim care order at a without notice hearing and the judge’s use of the s.37 jurisdiction to do so. In the circumstances of the case the judge’s actions were permissible given that an on notice hearing followed immediately after the without notice hearing and the court’s actions were entirely consistent with the child’s welfare. While other procedural routes could have been taken this did not make s.37 impermissible.