Memory lapse

In a recent telephone conversation with counsel, the question of whether or not to ask the court to bar the father from making any further applications for a residence order without the leave of the court was discussed. For a moment my memory of which section of the Children Act contained this provision escaped me, as I told counsel, and I referred to section 61. She kindly replied that the last time she checked, the provision was in section 91, as if it might recently have changed, which she obviously knew it had not. Oh well, age catches up with all of us...