What constitutes violence under Section 24(3) of the Family Law Act?

Violence as constructed within Section 24(3) (f) of the Family Law Act does not require direct physical injury. I adopt the analysis of Fitzgerald J. in Hill v. Hill (1987) 10 R.F.L. (3rd) 225, in which he concludes that the Family Law Act is a remedial stature that can be liberally construed to include within its meaning, an injury achieved by words and deeds: In my view the violence in this context must be such that it makes continuation of joint cohabitation in the matrimonial dwelling impractical. Violence in my view includes psychological assault upon the sensibilities of the other spouse to a degree which renders continued sharing of the matrimonial dwelling impractical. Where, as here, the conduct of the husband in written and spoken communication to the wife is calculated to produce and does in fact produce an anxiety state which puts the wife in fear of her husband’s behavior and impinges on her mental and physical health, violence has been done to her equilibrium as surely as if she had been struck by a physical blow.