What is the test for a parent complaining of estrangement?

Ontario, Canada


The following excerpt is from A.C. v. M.Z., 2010 ONSC 6473 (CanLII):

In Casademont v. Casademont (2007) 44 R.F.L. (6th) 287 (S.C.J.) the court concluded the onus is on a parent complaining of estrangement to show he or she made meaningful efforts to maintain a positive relationship with the adult child.

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