Family proceedings – Appeal. As a matter of principle, it was fundamentally wrong for the Family Court to be drawn into an analysis of factual evidence in proceedings relating to the welfare of children based upon criminal law principles and concepts. Taken with the likely untenable timetable imposed by the court, the Court of Appeal, Civil Division, in allowing the appellant father's appeal against the finding that he had used unreasonable force and unlawfully killed the mother, held that he had not been afforded a sufficiently fair trial in the Family Court.