Question juridique clé
Whether IV child supplements count as child allowances under Art. 285(2) ZGB and are covered by the divorce judgment as an enforcement title.
Solution extraite
IV child supplements are not child allowances within Art. 285(2) ZGB; the divorce judgment was not an enforcement title for those supplements.
Motifs extraits
Child allowances under Art. 285(2) ZGB are benefits paid in addition to the recipient's other income. Child supplements attached to social insurance benefits are different: they replace earned income and are intended to enable the insured person to continue meeting family support duties. The divorce judgment only ordered payment of child allowances and did not expressly address such social-insurance supplements.