In a previous Note in the Review, the current author noted the decision of the Judicial Committee of the Privy Council on appeal from New Zealand in B v Attorney-General of New Zealand  4 All ER 833 and its approach to the various duties of care which might arise out of allegations of child sexual abuse. However, the ascertainment of those duties is inevitably connected with the manner of proof of facts which leads to that process. In turn, that leads to a consideration of the standards of proof which govern that process. That process is further complicated by both the nature of the issue itself and the circumstances in which the allegations arise and the processes involved in its ascertainment. Those very issues were considered in the recent decision of the English Court of Appeal in Re T (Children) (Abuse: Standard of Proof)  2 FLR 838.