What is the test for finding that a parent who communicates at cross-purposes with their child's mother can not have joint custody?

Ontario, Canada


The following excerpt is from Lane v. Lane, 2002 CanLII 2794 (ON SC):

In Mulrooney v. Barker [2001] O.J. No.356, Duchesneau-McLachlan J. of the Ontario Court of Justice found mutual hostility between the parties who communicated at cross-purposes and therefore concluded that joint custody cannot be in the best interest of the child. This court does not refer to any case law in arriving at its decision.

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