What is the test for establishing a relationship between a child and their grandmother?

In Children’s Aid Society of Toronto v. VF, 2013 ONCJ 503, Justice Spence considered the interpretation to be applied to this aspect of the best interests analysis. Specifically, he considered whether a biological connection was sufficient to meet this branch of the test. He found that giving it the broadest interpretation the term “relationship” could include biological connection as well as inter-personal connections, however he goes on to find that there has to be something more than a biological relationship and that one must consider whether a child is connected in a meaningful way to the other person, at para 62 emphasis in original,: Obviously, there is a biological relationship between two of the children and the grandmother. However, there is certainly no inter-personal relationship between the grandmother (or any of the grandmother’s family in Jamaica) and these children. It seems to me that if we examine this from the perspective of these children, the existence of an inter-personal relationship, that is, whether the children themselves are connected in a meaningful way to another person, is more significant than mere biology, particularly where the children have never met the kin and do not even know of the kin’s existence.