In a family law case, is there any opinion evidence that a difficult relationship between the daughter and the daughter's biological father would be ameliorated by the granting of an order to adopt?

Ontario, Canada


The following excerpt is from B.D.H. v. S.A.M., 1981 CanLII 1582 (ON CJ):

[10] In Adams and Adams v. Andrews, there was opinion evidence that a difficult relationship between the daughter and the natural father would be ameliorated by the granting of the order sought. There was no such evidence before me. In addition, in that case, the potentially adoptive parents were said, in the evidence of the psychiatrist, to have an opportunity to provide a more secure milieu for the child were she adopted. Again, there was no such evidence before me. In fact, the only reason advanced by the mother for the adoption itself was to satisfy the request of the children for a change in their surname; and, with respect to the family situation and harmony, it was the evidence of the applicant that there would be no change in the advantages, possibilities or circumstances of the children were the application not to succeed.

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