Does a contempt finding need to be found on a first non-compliance of an access order?

Ontario, Canada


The following excerpt is from A.C. v. K.C., 2022 ONSC 1844 (CanLII):

It would be an unusual case where a contempt finding would be made on a first non-compliance of an access order. Accordingly, in a usual case on a first default, a warning, admonition, or a penalty in costs would generally be more appropriate: Jean v. O’Callaghan, 2017 ONSC 4027, at para. 11.

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