Claims for damages arising from conduct leading to the making of court orders cannot be maintained while those orders remain in force, as this constitutes an impermissible collateral attack. Even where execution of court orders may have been technically defective (here, absence of a warrant), subsequent valid orders providing authority for the same result may mean the defect caused no actionable damage. The scope of absolute privilege for inter-governmental communications in the course of Hague Convention child abduction proceedings was left open for determination with proper submissions.
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