The notion of 'family life' under Article 81 is not confined solely to families based on marriage and may encompass other de facto relationships2. In order to demonstrate that 'family life' exists in situations which do not constitute a legal relationship it is necessary to show a degree of 'constancy'3. Applying this approach, 'family life' has been found to cover a broad range of personal relationships including those between siblings4, grandparents and grandchildren5, an uncle and nephew6, and a child and his foster parents7, and continues to exist between children and parents following the separation of the parents, whether
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