On November 26, 2013, the Grand Chamber of the European Court of Human Rights ruled [3], by nine votes to eight, in X v. Latvia that Latvia had violated Article 8 (right to respect for private and family life) of the European Convention on Human Rights (European Convention) because its courts had not considered an arguable allegation of “serious risk” to a child when ordering the child’s return to Australia, her country of origin.  According to the press release [4], the Grand Chamber ruled that, in ordering the return of the child pursuant to the Hague Convention on the Civil Aspects of International Child Abduction of 25 October 1980 (Hague Convention), the Latvian courts had failed to apply the European Convention and Hague Convention “in a combined and harmonious manner.”  Citing the United Nations Convention on the Rights of the Child, the Grand Chamber also reaffirmed “that the best interests of the child had to be the primary consideration.”  In a joint dissenting opinion, eight judges reasoned that the Latvian courts “adequately responded to the [child’s mother’s] arguments and that the examination of the claims made by the applicant satisfied the procedural requirements imposed on them by Article 8 of the Convention.”