Is a relationship between a child and her mother beneficial to the child?

Ontario, Canada


The following excerpt is from Children and Family Services For York Region v. J.E., 2008 CanLII 51927 (ON SC):

Similarly, in C.A.S. of Ottawa-Carleton v. T.C. [5], Mackinnon J. noted “I cannot conclude that the relationship between [the child] and her mother is beneficial to [the child]. The fact that she would like to visit her mother, in the context of this case, goes to the fact that the relationship is meaningful, not that it is beneficial.”

In Native C.F.S. of Toronto v. K.W.H. [6], Murray J. was of the view that the determination of whether a parent’s relationship is “beneficial” to a child requires an assessment of that parent’s ability to support the child’s placement in a permanent home…if the evidence indicates that a biological parent…will not support that child’s placement in a permanent home (other than her own) and will put the child in a loyalty bind, then that is a very significant factor in determining whether an order providing for future access should be made…”.

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