Family member JR

Hi - can you please help me out in following issues:

Foreign national (C) arrived with student visa in 2007, extended until 2012 - variation extension application under 276ade was refused, FT UT JR permission refused, so did COA on 22/05/2015. C is under process to take the case to ECtHR within six months of refusal deadline should be 21/11/2015. Dated 01/09/2015 SSHD served C a 'notice of liabiliy for removal'.
Tell me what action can be taken or if any powerful ball left in C's hand. Can C serve pre-action protocol or JR against removal notice?

What do we do?
Thanks
S

Also see reply to identical post.