How have courts interpreted section 105(6) of the Children’s Aid Society of Toronto Act?

In Children’s Aid Society of Toronto v. J.G,. section 105(6) of the Act is explained as follows: a) A rigid approach based on the requirement that access must be “significantly advantageous” for the child is no longer applicable. Access to a child in extended Society care needs to be viewed through a global best interest test; b) The new access test permits the court to conduct a more holistic and comprehensive analysis of what is best for a child; c) A child’s best interests in connection with future access involve a delicate weighing and balancing of multiple factors. It is not a fact-finding mission and the exercise is not assisted by determining what the onus is or where it lies; and d) In considering whether a relationship is beneficial and meaningful the court can consider any factor, whether past, present or future (child’s best interest are not static). This would include the prospect of an openness order. [11]