The child was cared for by the maternal grandmother. The court was asked to make orders with regard to the extent of contact for natural mother, and father.
Held: In private Children Act proceedings it was generally inappropriate for the judge to order an investigation under s 37, which is a public law procedure. Cases which were not clearly urgent could not warrant such an order.
Times 11-Feb-1999, Gazette 03-Mar-1999,  EWCA Civ 723
England and Wales
Updated: 30 May 2022; Ref: scu.145638