Souratgar v. Lee, 720 F.3d 96 (2d Cir. 2013)
Article 20 | Domestic Violence | Degree of Violence | Grave Risk to Child | Syariah Law
This case deals in part with the claim that the prospect of having to litigate custody in Syariah courts violates the provisions of Article 20, prohibiting the return of children if the return would be contrary to the protection of human rights and fundamental freedoms. There is also a substantial discussion as to what constitutes domestic violence sufficient to warrant a refusal to return a child.