236 Letter from Sarah Mitchell, Minister for Education and Early Learning to the National Children’s Commissioner, Anne Hollonds, 1 March 2022. 237 Letter from Sarah Mitchell, Minister for Education and Early Learning to the National Children’s Commissioner, Anne Hollonds, 1 March 2022. 238 Letter from Lauren Moss, Minister for Education to the National Children’s Commissioner, Anne Hollonds, 22 February 2022. 239 Australian Government Department of Education, Skills and Employment, National Framework for Managing COVID-19 in Schools and Early Childhood Education and Care (Report, January 2022) <https:// www.education.gov.au/covid-19/resources/ national-framework-managing-covid19>. 240 Victoria Department of Education and Training, Operations Guide Victorian Government Schools (Report, 18 August 2020) 13 <https://www. parliament.vic.gov.au/images/stories/committees/ paec/COVID-19_Inquiry/Tabled_Documents_ Round_2/School-Operations-Guide_-Term_3_1. pdf>. 241 Letter from Lauren Moss, Minister for Education to the National Children’s Commissioner, Anne Hollonds, 22 February 2022. 242 Letter from Stuart Roberts, Minister for Employment Workforce, Skills and Small and Family Business, Acting Minister for Education and Youth to the National Children’s Commissioner, Anne Hollonds, 28 February 2022. 243 Letter from Grace Grace, Minister for Education, Minister for Industrial Relations, Minister for Racing to the National Children’s Commissioner, Anne Hollonds, 24 February 2022. 244 Letter from Grace Grace, Minister for Education, Minister for Industrial Relations, Minister for Racing to the National Children’s Commissioner, Anne Hollonds, 24 February 2022. 110 | 245 Letter from Grace Grace, Minister for Education, Minister for Industrial Relations, Minister for Racing to the National Children’s Commissioner, Anne Hollonds, 24 February 2022. 246 Letter from Sarah Mitchell, Minister for Education and Early Learning to the National Children’s Commissioner, Anne Hollonds, 1 March 2022. 247 Letter from Sarah Mitchell, Minister for Education and Early Learning to the National Children’s Commissioner, Anne Hollonds, 1 March 2022. 248 Australian Human Rights Commission, Human Rights Brief No. 1 (Web Page, 2023) <https:// humanrights.gov.au/our-work/human-rightsbrief-no-1#:~:text=In%20the%20case%20of%20 actions,set%20out%20in%20the%20CRC>. 249 Australian Human Rights Commission, ‘Permissible limitations on rights’ (Web Page, 2023) <https://humanrights.gov.au/our-work/ rights-and-freedoms/permissible-limitationsrights>. 250 UNICEF, Convention on the Rights of the Child: The children’s version (Web Page, 24 January 2023) <https://www.unicef.org/sop/convention-rightschild-child-friendly-version#:~:text=Children%20 have%20the%20right%20to%20the%20best%20 health%20care%20possible,to%20stay%20safe%20and%20healthy>. 251 The Hague Convention on the Civil Aspects of International Child Abduction, opened for signature 25 October 1980, 1343 UNTS 89, (entered into force 1 December 1983) <https://www.refworld. org/docid/3ae6b3951c.html>.