The term "undue hardship" indicates a high threshold; it means hardship that is exceptional, excessive or disproportionate in the circumstances. The question is not whether some hardship may be caused to the Respondent because of his obligation to support his biological child. The question is whether it is undue: Campbell v. Chappel, [2002] N.W.T.J. No. 96 (N.W.T.S.C.) at para. 8.
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