In Native C.F.S. of Toronto v. K.W.H. [6], Murray J. was of the view that the determination of whether a parent’s relationship is “beneficial” to a child requires an assessment of that parent’s ability to support the child’s placement in a permanent home…if the evidence indicates that a biological parent…will not support that child’s placement in a permanent home (other than her own) and will put the child in a loyalty bind, then that is a very significant factor in determining whether an order providing for future access should be made…”.
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