Question juridique clé
Whether the former husband had standing to challenge approval of the children's surname change by administrative appeal.
Solution extraite
No. Because he could protect any asserted name-rights interest through the civil action under Art. 30(2) ZGB, he lacked a protectable interest for administrative judicial review.
Motifs extraits
Administrative appeal is unavailable when the same interest can be fully vindicated in civil proceedings. The appellant's reliance on alleged name appropriation was therefore not sufficient to create standing.