How have the courts treated the issue of "moral duty" in s. 4 of the Mental Health Act?

Nemetz J.A. did not pursue the idea of moral duty, but proceeded to deal with circumstances which were relevant to character and conduct of the kind referred to in s. 4 of the Act and held that “there is no legal foundation for making an award in this case”. Thus no relief was given the son on the basis of any “moral duty as described in Walker v. McDermott”. (I should mention that I cannot find there the phrase “moral duty”.) I think that, when Nemetz J.A. referred to “moral duty as described in Walker v. McDermott”, he was referring to a submission made — my notes show that such a submission was made — that there was in the case before him a moral duty apart from need and was not stating his own opinion that there was such a duty.