The fourth factor in the Fielding framework is that the child exhibits most of the alienated child behaviours. A finding of parental alienation may, however, be made where although the child is not yet exhibiting behaviours of an alienated child, the alienating parent is engaged in a campaign to deprive the child from having a relationship with the targeted parent (Khan v. Kong, 2007 CanLII 61091, affirmed 2009 ONCA 21).
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