“The Divisional Court in JSR v Children’s Aid Society of Ottawa, 2021 ONSC 630, at para 51, held that if some ongoing contact with a parent would be in the child’s best interests, the CYFSA puts an obligation on the court to make a specific order with respect to that access and not leave it to the discretion of one of the litigants.”
The Children’s Aid Society of Ottawa v. S. B-M. et al, 2025 ONSC 1117 (CanLII) at 31