Family proceedings – Orders in family proceedings. Following the death of a child, the local authority made an application for a care and supervision in relation to the other child of the family. In the application, the local authority sought findings that the dead child had sustained non-accidental injuries at the hands of the father. The Family Division held that the threshold criteria under s 31 of the Children Act 1989 had been made out nevertheless the living child should be returned to the care of the mother with the possibility of making of a supervision order.