The family unit need not be confined to the marital relationship
In 1994 in Keegan v. Ireland, the European Court of Human Rights noted that the family unit need not be confined to the marital relationship to enjoy protection but that a de facto family existed and enjoyed protection as well as rights, regardless of its marital status
More information at http://www.hrcr.org/safrica/childrens_rights/keegan_ireland.html
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