When will a court order a parent to attend counselling for their child who is refusing to attend?

In Testani v. Haughton, Justice Jarvis J. stated that resistance to therapy was an important factor to consider, but that it was not the determining factor as to whether such an order should be made. There may be various reasons for a parent’s resistance to therapeutic intervention; the parent may not be satisfied that the cause of the breakdown in the child-parent relationship has been properly identified; the parent may feel that therapy is premature and that other steps must first be completed; the parent may lack the financial resources to retain the recommended therapist, and/or; the parent may not wish to have to physically force a resistant child to attend counselling. The court should assess the likelihood that a parent will comply with a therapeutic order once it is made, despite that parent’s professed refusal to engage.