In Robert L. v. Superior Court (1996) 45 Cal.App.4th 619, the court addressed a prior version of section 361.5, subdivision (a), which provided in pertinent part: "'Whenever a minor is removed from a parent's or guardian's custody, the juvenile court shall order the probation officer to provide child welfare services to the minor and the minor's parents or guardians for the purpose of facilitating reunification of the family within a maximum time period not to exceed 12 months.'" (Robert L., at p. 628, first ) In Robert L., three children were detained after they were found in a very dirty home without food. ( Robert L. v. Superior Court, supra, 45 Cal.App.4th at p. 621.) The father was incarcerated at the time of the children's detention, and he never requested or received reunification services prior to the setting of a permanency planning hearing pursuant to section 366.26. (Robert L., at pp. 622, 624.) The father then challenged the order setting the section 366.26 hearing, arguing, inter alia, that he had never been offered reunification services, contrary to the mandate in former subdivision (a) of section 361.5 that such services should be provided to "parents." (Robert L., at pp. 626-627.) The court in Robert L. concluded that this mandate was inapplicable to the father because he had never requested custody of the children, and thus providing reunification services to him would not have furthered the statutory purpose of "'facilitating reunification of the family . . . .'" ( Robert L. v. Superior Court, supra, 45 Cal.App.4th at p. 628.) In so concluding, the court in Robert L. followed In re Terry H. (1994) 27 Cal.App.4th 1847, 1854-1856, in which the court had similarly held on the basis of the then applicable statutory language that "a noncustodial parent who does not seek custody of the children is not entitled to reunification services." (Robert L., at p. 628.)