What is the test for a parent to make an offer to settle their child's custody matter?

Ontario, Canada


The following excerpt is from J.C.M. v. K.C.M., 2016 ONCJ 551 (CanLII):

[42] Once the father made his offer to settle, the mother had the opportunity of resolving the case by making a counter-offer that excluded the custody term. This would have likely led to a resolution of the case. Instead, the mother did not make an offer to settle. The failure to make an offer to settle is unreasonable behaviour. See: Laing v. Mahmoud, 2011 ONSC 6737.

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