Family proceedings – Orders in family proceedings. The local authority applied for a care order in respect of a young child, N, as a result of his attendance at hospital following his collapse. There was radiological evidence of possible hypoxic-ischemic brain injury. The Family Court held that, on the evidence, N's injuries had resulted from an innocent, but ill-advised, resuscitative shake by his mother. However, in the circumstances, the threshold criteria of s 31(2) of the Children Act 1989 were not satisfied and, therefore, the application for a care order would be dismissed, with the consequence that N would return to the care of his mother and father.