What is the case law on hearsay under the Venner doctrine?

Ontario, Canada

The following excerpt is from Catholic Children’s Aid Society of Metropolitan Toronto v. M.M., 1981 CanLII 1975 (ON CJ):

[27] Any increase in their value or weight under the Ares v. Venner doctrine would depend on a cautious search for circumstances that would tend to guarantee the trustworthiness of the hearsay and for circumstances that would suggest a practical necessity for a departure from the accepted standards of fairness that allow an opposing party to challenge and test allegations, perceptions and opinions by way of cross-examination.

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