In Re Clarke [2016] EWCOP 46, Peter Jackson J has confirmed that the High Court can exercise jurisdiction over British nationals abroad who lack capacity and require protection, but who are no longer habitually resident in England and Wales and cannot therefore be subject to the jurisdiction of the Court of Protection given that its welfare jurisdiction is expressly limited to those who are habitually resident in England and Wales (or who are present here in certain defined circumstances). This judgment is not hugely surprising in light of the decision of Holman J in Al-Jeffery [2016] EWHC 2151 (Fam) in which this jurisdiction was identified as existing in relation to those with capacity but who were vulnerable, but this confirmation is useful in terms of maximising the powers of the courts to take effective steps where adults have been kidnapped out of the jurisdiction.