UK Courts has refered to Zambrano,see http://www.bailii.org/uk/cases/UKUT/IAC ... geria.html
You don't have to wait for the ukba, however i agree that it is unlawful for ukba to reject applications recieved by the EEA departments claiming that there are currently no documentation to issue, that will be subject to appeals/JR.
Also using the FLR(O) to make an application based on zambrano is the appropriate way, as there is a CLEAR DOCUMENTATION to issue (DLR).
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