What is the difference between a change in parenting arrangements between a child and his non-custodial parent?

Ontario, Canada

The following excerpt is from Peet v. Zolob, 2014 ONSC 5748 (CanLII):

Third, as emphasized in authorities such as Holt v. Anderson, supra, not each and every proposed change, and corresponding alteration in the status quo, will be of equal magnitude and concern. As Justice Lane observed at paragraph 11 of that decision, “a case of bouncing a small and bewildered child back and forth between parents”, with significant disruptions to an infant’s surroundings and ongoing contact with the non-custodial parent, has to be distinguished from a variation, supported by the OCL, where “a child of the age of reason …wants a return to an arrangement allowing [him or] her to see more of [his or] her father than the arrangement imposed by the mother permits”, and where the new arrangement “involves no great change, no moving from one city to another and no separation from either parent”.

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