MENNESSON v. FRANCE JUDGMENT 15 the children of the legal parent-child relationship with the mother and father recognised under Californian law and did not prevent the applicants from living together in France. Furthermore, their effective and affective family life was “legally clandestine”. This was particularly shocking in the case of the first applicant, who was deprived of recognition of the legal parent-child relationship with the third and fourth applicants by the refusal to record the particulars of the children’s birth certificates in the French register of births, marriages and deaths even though he was their biological father and there was nothing to prevent that relationship from being officially recorded. What was more, the applicants had no other possibility of having the family ties legally established, since the case-law of the Court of Cassation precluded not only registration of the birth details but also adoption or recognition of their de facto enjoyment of status (possession d’état). In that respect their case was clearly distinguishable from the situation examined by the Court in Shavdarov v. Bulgaria (no. 3465/03, 21 December 2010). 68. The applicants also observed that the measure in question had “grossly disproportionate consequences” for the situation of the third and fourth applicants: without recognition of a legal parent-child relationship with the first two applicants, they did not have French nationality, did not have a French passport, had no valid residence permit (even if, as minors, they could not be deported), and might find it impossible to obtain French nationality and thus be ineligible to vote and ineligible for unconditional leave to remain in France; they could also be prevented from inheriting under the first two applicants’ estate. Furthermore, in the event of the first applicant’s death or should the first two applicants separate, the second applicant would be deprived of any rights in respect of the children, to their and her own detriment. In order to carry out administrative tasks for which French nationality or an official legal parent-child relationship were required (registration of the children for social-security purposes, enrolment at the school canteen or outdoor centre, or applications for financial assistance from the Family Allowances Office), they had to produce the US birth certificates together with an officially sworn translation in order to prove that the children were theirs, and the success of their application depended on the good will of the person dealing with it. The applicants pointed out in this connection that the advocate-general had recommended, before the Court of Cassation, recognising the legal parent-child relationship between the applicants, particularly on the ground of the children’s best interests, and that the Paris Court of Appeal itself had observed that the situation would create practical difficulties for the Mennesson family. They also referred to the report of the Conseil d’État of 2009 on the review of bioethical laws, which indicated that “in practice, families’ lives [were] more complicated without registration, because of the formalities that had to be completed on various occasions in life”. They added that, in Wagner and J.M.W.L. (cited above, § 132), the Court had acknowledged that in this type