What is the test for adding a police enforcement clause to a final order?

Ontario, Canada


The following excerpt is from M.R.-J. v. K.J., 2020 ONCJ 305 (CanLII):

The court is not prepared to include a police enforcement clause at this time. The court adopts the reasoning and approach taken by Justice Pazaratz in Patterson v. Powell, 2014 ONSC 1419. A police enforcement order is an order of last resort to be made sparingly and in exceptional circumstances. It can frighten children and polarize a difficult situation. However, the court will reconsider the father’s request for a police enforcement order if there is continued and repeated non-compliance with the final order. Order:

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