 On one view (Liao 2006, 2015) children have a right to be loved on grounds of the huge instrumental value that love has for childhood wellbeing and development. He claims that the empirical literature shows that children who lack love suffer in terms of physical health and development, learning ability, interest in interacting with the environment, ability to sleep and mental health. The right is said to be held by each child primarily against her biological biological parents, but all of us have secondary duties to ensure that all children are loved. A similar claim, that love is irreplaceably instrumental to children leading meaningful childhoods has been recently endorsed (Ferracioli 2014) but also criticized (Grahle 2016).