What is the test for undue hardship when a father has to support his biological child?

Northwest Territories, Canada


The following excerpt is from Eliuk v Grymaloski, 2008 NWTTC 13 (CanLII):

The term "undue hardship" indicates a high threshold; it means hardship that is exceptional, excessive or disproportionate in the circumstances. The question is not whether some hardship may be caused to the Respondent because of his obligation to support his biological child. The question is whether it is undue: Campbell v. Chappel, [2002] N.W.T.J. No. 96 (N.W.T.S.C.) at para. 8.

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