What is the impact of past conduct of the Respondent on parenting skills and access to the children?

Relying on cases noted below[1], counsel have made submissions with which I agree including: past conduct of the Respondent is relevant to her parenting skills and the past conduct in question here is of the most serious nature; access is the right of the children and must only be ordered when it will benefit them; and the relevant factors in Gordon v. Goertz all favour relocation. Of the three cases referred to in which criminal charges were laid, they all involved the mother of the children as victim. Counsel advised she had not been able to find any case in which the children had been the victim. It is only logical to conclude that when the violence is against the children, the past conduct of the Respondent is even more important and the potential positive effect on the children if allowed to move is even more profound.