What is the test used to determine whether a parent took sufficient steps to ensure access to a child?

Ontario, Canada


The following excerpt is from Baylis v. Shonek, 2018 ONCJ 445 (CanLII):

26. In Jackson v. Jackson, [2016] O.J. No. 2870, a contempt case, Justice Chappel suggested a four question inquiry at para. 63(d) to determine whether a parent took sufficient steps to ensure access took place:

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