Family proceedings – Orders in family proceedings. The present test cases raised various substantive and procedural questions in relation to the interface between care proceedings brought in the Family Court, pursuant to Pt IV of the Children Act 1989, and the requirements of art 5 of the European Convention on Human Rights. The Family Division held that the situation of the young or very young did not involve a confinement, gave a rule of thumb on at what point in the child's development a child became confined, and gave guidance on matters of process and procedure.