If the court is being asked to make a decision about the treatment then it could also authorise any necessary deprivation of liberty. I didn’t find any examples when I looked there now, but it’s mentioned in Practice Guidance (Court of Protection: Serious Medical Treatment) [2020] EWCOP 2:
- Separately to the matters set out above, an application to court may also be required where the proposed procedure or treatment is to be carried out using a degree of force to restrain the person concerned and the restraint may go beyond the parameters set out in sections 5 and 6 Mental Capacity Act 2005. In such a case, the restraint will amount to a deprivation of the person’s liberty and thus constitute a deprivation of liberty.[6] The authority of the court will be required to make this deprivation of liberty lawful.