What is the mother's obligation to actively encourage access?

Ontario, Canada


The following excerpt is from Zhang v. Guo, 2019 ONSC 5381 (CanLII):

The mother has an obligation to actively encourage access. The residential parent’s responsibility goes beyond simply accommodating access, making the child available for access, and encouraging the child to comply. The residential parent must require that access occur and actively facilitate it (Jackson v. Jackson, 2016 ONSC 3466, at para. 63). The mother cannot abdicate her role as a parent. The mother’s subjective belief does not relieve her from complying with her legal obligation to actively facilitate access. Her legal obligation includes compliance with the telephone access ordered by the motion judge.

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