I have carefully reviewed the summary of principles set out by Jarvis J. in Testani v. Haughton 2016 ONSC 5827 (CanLII) at para. 18 that he suggests guide a court’s decision as to whether to order reunification therapy: a. Such orders should be made sparingly. b. There must be compelling evidence that the therapy will be beneficial. c. The request must be adequately supported by a detailed proposal identifying the proposed counsellor and what is expected. d. Resistance to therapy is an important factor, but is not determinative as to whether such an order should be made; e. Where a clinical investigation or an assessment is underway, no order should be made pending their conclusion. f. Wherever practical, appropriate direction should be given to the counsellor/therapist and a report made to the court.
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