In what circumstances will a judge find a mother contempt of court for refusing to abide by a parenting order?

In Godard v. Godard [6]the Court of Appeal recently dealt with a very similar situation and upheld a finding of contempt. In that case the motion judge had held that it was inappropriate of the mother to leave a 12 year old child with the impression that she could decide starting at the age of 12 whether she wished to continue with access to her father. He held that refusing to abide by the access order by leaving it up to the child and “effectively abandoning her parental authority on the issue of access” and allowing the behaviour of the child to sometimes result in positive consequences for her justified a finding of contempt. In that case the finding of contempt was justified because of the history of the case which had shown that alternative approaches were of no effect.