iv. Article 5, paragraph 1(d)

Deprivation of liberty is also justified in the event of “the detention of a minor by lawful order for the purpose of educational supervision or his lawful detention for the purpose of bringing him before the competent legal authority”. There are two kinds of measures. In this regard “educational supervision” does not include only educational measures and educational recommendations⁸¹² but also juvenile detention. On the other hand, detention of a minor shall be any deprivation of liberty aimed at bringing a minor before the competent legal authority, which does not necessarily have to be a court, in order to enforce all necessary measures (for instance, separation of a child from violent parents) and not only because a minor committed some criminal offence.⁸¹³