H-L (A Child) [2013] EWCA Civ 655 (13 June 2013)

Allowing in part an appeal against the refusal to allow experts to be instructed in care proceedings. The CA considered the new test under rule 25.1 FPR 2010 concerning expert evidence. The CA held that ‘necessary’ means necessary. Munby LJ expanded this quoting from Re P (Placement Orders: Parental Consent) [2008] EWCA CIV 435 which holds necessary has ‘the connotation of the imperative, what is demanded rather than what is merely optional or reasonable or desirable.