What undertakings might have been imposed in a return order application?

[23] In Cannock v. Fleguel, supra, the court at paragraph [28] made a general observation that imposition of appropriate undertakings may modify a potential risk of harm of a return order, so that Article 13(b) grounds will not be made out. The court did not deal with specific undertakings that might have been appropriate in that case, because the appeal was taken before the judge at first instance had considered the undertakings issue.