What is the appropriate date for the consent of the left behind parent in cases of openended or indeterminate consent?

In cases of open-ended or indeterminate consent, the date is usually fixed as when the left behind parent first formally asserted his right (Barzilay v. Barzilay, 600 F.3d 912 (2010) or demanded the child’s return (Yang v. Tsui, supra).

Bazargani v. Mizael, 2015 ONCA 517, like the case presently before this court, involved an open-ended consent agreement. One parent was permitted to leave Australia with their child for an indeterminate period. In the absence of a pre-determined return date, the court relied on the explicit revocation of consent by the wronged parent (paras. 9, 22).