Is mobility a presumption in favour of the custodial parent?

In Gordon v. Goertz, the court was dealing with mobility in the context of an application to vary an existing custody order. The mother had previously obtained sole custody, with generous access to the father; she applied to vary the order to permit her to relocate to Australia. The court indicated that while there was no legal presumption in favour of the custodial parent, nevertheless the views of the custodial parent are “entitled to great respect and the most serious consideration”. The court said at paragraph 48: While a legal presumption in favour of the custodial parent must be rejected, the views of the custodial parent, who lives with the child and is charged with making decisions in its interest on a day-to-day basis, are entitled to great respect and the most serious consideration. The decision of the custodial parent to live and work where he or she chooses is likewise entitled to respect, barring an improper motive reflecting adversely on the custodial parent’s parenting ability.