Justice Belch stated in the case of Lyon v. Lyon, [2004] O.J. No. 1645 at paragraph 47: Those who practice family law know that changing a child's name is an emotional flashpoint to be avoided if at all possible. These parties recognize, as have earlier court decisions, that education, health, religion and residence are major child rearing decisions. I find that the issue of a child's surname is also a major child rearing decision and should be added to that list.
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