What is the test for alienation of a parent?

Ontario, Canada


The following excerpt is from J.H. v. L.G., 2011 ONSC 2476 (CanLII):

The comments of the court in Milanizadeh v. Zeinali,[10] are applicable here: 107. From the outset, it must be understood that true alienation does not often exist. More often, children are realistically estranged from one parent or the situation is one of high conflict where both parents show varying degrees of alienating behavior but the children themselves are not alienated. Conclusions

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