What is the test for contempt in a family law case?

The court has to exercise caution in contempt applications in family matters. There are often significant, emotional problems in connection with custody and access. In the case of Salloum v. Salloum (1994) 154 A.R. 65, there was a contempt proceeding for failing to obey a court order related to access. The court said at p. 67: In custody disputes, the court's power to find a litigant in contempt should be exercised sparingly. Again at p. 68 However, by long tradition, the court exercises restraint in family law cases. In custody cases, the court usually requires an intentional breach of the court order . . . The reasoning in these cases, which reasoning I adopt, is that restraint is appropriate given the twin objectives of protecting both the best interests of the children and the administration of justice. As frustrating as it must be for a parent whose court ordered access is sterilized the court's focus is on the interest of the children, not on the behaviour of the parents. Children are better off if the parents are not in jail or paying fines. That was a decision of a single judge in Alberta.