Very strict. The Court of Appeal rejected an appeal by the mother, who had abducted her young child to England, against a High Court of Justice order for the minor’s return to Israel. Although the court of Appeal did recognize that there had been an escalation of violence, and that there were random and indiscriminate attacks, concentrating on major urban centres and public transport, it did say life went on as usual, and rejected the ‘grave risk’ of physical harm argument related to the terrorist attacks in Israel. It said that the number of deaths from road traffic accidents exceeded that from terror attacks.