What is the current state of the law in Canada on a tort where a party is sued by their ex-wife for interfering with their access?

In Frame v. Smith, 1987 CanLII 74 (SCC), [1987] 2 S.C.R. 99, the majority held that such a tort does not exist in Canadian law. In discussing the development of a possible remedy to assist parents whose access rights have been interfered with, Lamer, J. identified the desirability of avoiding exactly the type of lawsuit initiated by the plaintiff. At p. 110 he wrote: It would, of course, be possible for the courts to devise a new tort to meet the situation. And the temptation to do so is clearly present, for one cannot help but feel sympathy for the appellant and others in like situations. But there are formidable arguments against the creation of such a remedy. I have already mentioned the undesirability of provoking suits within the family circle. The spectacle of parents not only suing their former spouses but also the grandparents, and aunts and uncles of their children, to say nothing of close family friends, for interfering with rights of access is one that invites one to pause. The disruption of the familial and social environment so important to a child’s welfare may well have been considered reason enough for the laws inaction, though there are others.