proceedings before the courts. Ireland In Ireland, a court may, of its own motion or on application, order that no proceedings, either of a certain type or at all, may be issued by a certain person without leave of that court or some other court, for a specified time, or indefinitely. Such an order is referred to in legal circles as an Isaac Wunder order after Isaac Wunder who made several claims against the Hospitals Trust claiming sweepstakes prizes, but the claims were found to be groundless and the case deemed frivolous or vexatious. He was prohibited from taking further High Court proceedings in the action without leave of the court. New Zealand In New Zealand a person may be declared a vexatious litigant by a High Court Judge on the application of the Attorney-General. A vexatious litigant must then apply to a High Court Judge for leave to commence any action. A decision by the High Court whether or not to grant leave cannot be appealed. United Kingdom England and Wales In England and Wales there are two methods to control vexatious litigants: Civil restraint orders (made by the courts themselves on the application or their own initiative); and Vexatious litigants orders (made by the High Court under section 42 of the Senior Courts Act 1981 on the application of HM Attorney-General). His Majesty's Courts and Tribunals Service maintains a list of vexatious litigants and those subject to a civil restraint order. Civil restraint orders Courts in England and Wales have the means of escalating the sanctions against a litigant who makes applications to the court that are "totally without merit". Civil restraint orders allow courts to forbid applications for court hearings without the permission of a judge. There are three types of CRO: limited, extended and general, with different scopes of application. Further applications totally without merit can lead to the withdrawal of the right of appeal. Harassment of the court and court officials can lead to a penal prohibition notice, prohibiting the litigant from contacting or approaching the court without permission. Vexatious litigant orders Section 42 of the Senior Courts Act 1981 provides the High Court with the power to make an order restricting the ability of a person to undertake litigation without leave of the High Court. The High Court may make a civil proceedings order, a criminal proceedings order or an all proceedings order. A