What is the test for establishing a positive grandparent-grandchild relationship?

Ontario, Canada


The following excerpt is from Torabi v. Patterson, 2016 ONCJ 210 (CanLII):

[55] In Giansante v. Dichiara, Nelson J. summarized these principles in the following three-part test: 1. Does a positive grandparent-grandchild relationship already exist? 2. Has the parent's decision imperilled the positive grandparent-grandchild relationship? 3. Has the parent acted arbitrarily?[18]

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