What is the burden of establishing supervised parenting time?

Ontario, Canada


The following excerpt is from L.S. v. M.A.F., 2021 ONCJ 554 (CanLII):

[40] The person seeking supervised parenting time bears the burden of establishing that supervision is necessary. See: Klymenko v. Klymenko, 2020 ONSC 5451.

[41] Supervised parenting time is usually a temporary arrangement. However, when the court does not expect the risks addressed by supervision to diminish, it is appropriate to order long-term supervision of access. See: Tuttle v. Tuttle, 2014 ONSC 5011.

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