“… to trigger the duty to investigate. The TCRs should not have been refused. The substantive breach was the failure to ‘reunify’ (see TP and KM v United Kingdom (2002) 34 EHRR 2 at paragraph 83).…”
“…although a breach of those rights can be effected by a failure to adopt a fair procedure: see, e.g., TP and KM v United Kingdom (ECtHR Application No 28945/95) (2002) 34 EHRR 2 at [83]; and P, C and S v United Kingdom (ECtHR Application No 56547/00) (2002) 35 EHRR 31 at [136]-[137]).…”