What is the current state of the law on delay and/or delay for a child's return?

Ontario, Canada


The following excerpt is from U.K. v. N.A., 2021 ONCJ 73 (CanLII):

Mere delay, in itself without more (and particularly where the left behind parent later moves for the child’s return within the 12 months period after the removal or retention), will likely be insufficient[5]. See Ibrahim v. Girgis, 2008 ONCA 2328.

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