CCPR/C/GC/35 only some instances of which take place in connection with civil or criminal proceedings within the scope of article 14. The procedural requirements of paragraphs 2 to 5 of article 9 apply in connection with proceedings falling within the scope of article 14 only when actual arrest or detention occurs.172 62. Article 24, paragraph 1, of the Covenant entitles every child “to such measures of protection as are required by his status as a minor, on the part of his family, society and the State”. That article entails the adoption of special measures to protect the personal liberty and security of every child, in addition to the measures generally required by article 9 for everyone.173 A child may be deprived of liberty only as a last resort and for the shortest appropriate period of time.174 In addition to the other requirements applicable to each category of deprivation of liberty, the best interests of the child must be a primary consideration in every decision to initiate or continue the deprivation. 175 The Committee acknowledges that sometimes a particular deprivation of liberty would itself be in the best interests of the child. Placement of a child in institutional care amounts to a deprivation of liberty within the meaning of article 9.176 A decision to deprive a child of liberty must be subject to periodic review of its continuing necessity and appropriateness. 177 The child has a right to be heard, directly or through legal or other appropriate assistance, in relation to any decision regarding a deprivation of liberty, and the procedures employed should be childappropriate.178 The right to release from unlawful detention may result in return to the child’s family or placement in an alternative form of care that accords with the child’s best interests, rather than simple release into the child’s own custody. 179 63. In the light of article 2, paragraph 1, of the Covenant, States parties have an obligation to respect and to ensure the rights under article 9 to all persons who may be within their territory and to all persons subject to their jurisdiction. 180 Given that arrest and detention bring a person within a State’s effective control, States parties must not arbitrarily or unlawfully arrest or detain individuals outside their territory. 181 States parties must not subject persons outside their territory to, inter alia, prolonged incommunicado detention or 172 173 174 175 176 177 178 179 180 181 18 263/1987, González del Río v. Peru, para. 5.1; 1758/2008, Jessop v. New Zealand, paras. 7.9–7.10. See general comments No. 17, para. 1, and No. 32, paras. 42–44. See concluding observations: Czech Republic (CCPR/C/CZE/CO/3, 2013), para. 17; Convention on the Rights of the Child, art. 37 (b). 1069/2002, Bakhtiyari v. Australia, para. 9.7; see Convention on the Rights of the Child, art. 3, para. 1. See Committee on the Rights of the Child, general comment No. 10, para. 11; United Nations Rules for the Protection of Juveniles Deprived of their Liberty, para. 11 (b). In contrast, normal supervision of children by parents or family may involve a degree of control over movement, especially of younger children, that would be inappropriate for adults, but that does not constitute a deprivation of liberty; neither do the ordinary requirements of daily school attendance constitute a deprivation of liberty. See paragraph 12 above; Convention on the Rights of the Child, arts. 37 (d) and 25. General comment No. 32, paras. 42–44; Committee on the Rights of the Child, general comment No. 12, paras. 32–37. UNHCR, Detention Guidelines (note 45 above), para. 54 (“Where possible [unaccompanied or separated children] should be released into the care of family members who already have residency within the asylum country. Where this is not possible, alternative care arrangements, such as foster placement or residential homes, should be made by the competent child care authorities, ensuring that the child receives appropriate supervision”). General comment No. 31, para. 10. See ibid.; 52/1979, Saldías de López v. Uruguay, paras. 12.1–13; R.13/56, Celiberti de Casariego v. Uruguay, para. 10.1–11; 623,624,626,627/1995, Domukovsky et al. v. Georgia, para. 18.2.