Myerson v Myerson [2008] EWCA Civ 1376, [2008] All ER (D) 121 (Dec)
A judge who has made a consent order at the conclusion of a financial dispute resolution can only: (i) set up a further FDR appointment; (ii) make a consent order; or (iii) make an order for further directions. Where, at the end of the appointment, the judge is presented with a contract which needs to be converted into an order, any disagreement as to how the contract should be expressed can be referred to the FDR judge for determination. However, where the contract presented to the judge at the conclusion of the FDR is incomplete, in that there are subsidiary or peripheral issues to be agreed (or to be determined by the court), the dispute must be listed before another judge. Issues of enforcement, and applications to vary or set aside the consent order achieved at the FDR appointment, must be listed before another judge.
