Molshree Sharma in her February Illinois Bar Journal article, “When Courts Create Rules of Return,” notes that courts have sometimes ordered the return of a minor child under specific conditions that the petitioning parent must comply with to balance the competing concerns of ensuring the return of minor children to their habitual residence with preventing or ideally eliminating grave harm. These conditions are typically called “ameliorative measures” or “undertakings.” In her article, Sharma assesses the split in the U.S.

The Illinois Supreme Court Rules Committee will hear comments on submitted proposals on Thursday, April 9, 2026, at a public hearing beginning at 10 a.m. at the Administrative Office of the Illinois Courts, 222 N. LaSalle Street, 13th Floor, in Chicago. All proposals must be approved by the Illinois Supreme Court before they can take effect. The hearing will be livestreamed here.

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