22 MENNESSON v. FRANCE JUDGMENT 86. The Court considers that a distinction has to be drawn in the instant case between the applicants’ right to respect for their family life on the one hand and the right of the third and fourth applicants to respect for their private life on the other hand. (β) The applicants’ right to respect for their family life 87. With regard to the first point, the Court considers that the lack of recognition under French law of the legal parent-child relationship between the first and second applicants and the third and fourth applicants necessarily affects their family life. It notes in this regard that, as pointed out by the applicants, the Paris Court of Appeal acknowledged in this case that the situation thus created would cause “practical difficulties” (see paragraph 24 above). It also observes that, in its report of 2009 on the review of bioethical laws, the Conseil d’État observed that “in practice, families’ lives [were] more complicated without registration, because of the formalities that had to be completed on various occasions in life” (see paragraph 68 above). 88. Accordingly, as they do not have French civil-status documents or a French family record book the applicants are obliged to produce – nonregistered – US civil documents accompanied by an officially sworn translation each time access to a right or a service requires proof of the legal parent-child relationship, and are sometimes met with suspicion, or at the very least incomprehension, on the part of the person dealing with the request. They refer to difficulties encountered when registering the third and fourth applicants with social security, enrolling them at the school canteen or an outdoor centre and applying to the Family Allowances Office for financial assistance. 89. Moreover, a consequence – at least currently – of the fact that under French law the two children do not have a legal parent-child relationship with the first or second applicant is that they have not been granted French nationality. This complicates travel as a family and raises concerns – be they unfounded, as the Government maintain – regarding the third and fourth applicants’ right to remain in France once they attain their majority and accordingly the stability of the family unit. The Government submit that, having regard in particular to the circular of the Minister of Justice of 25 January 2013 ..., the third and fourth applicants could obtain a certificate of French nationality on the basis of Article 18 of the Civil Code, which provides that “a child of whom at least one parent is French has French nationality”, by producing their US birth certificates. 90. The Court notes, however, that it is still unclear whether this possibility does actually exist. Firstly, it notes that according to the very terms of the provision referred to, French nationality is granted on the basis of the nationality of one or the other parent. It observes that it is specifically the legal determination of the parents that is at the heart of the application

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