November 3, 2022 – Voice of the Child Reports

“A VOCR is a report intended to provide information about a child’s views and preferences for use in resolving parenting disputes. Generally non-evaluative, a VOCR is not comparable to a clinical investigation such as that conducted by Ms. Garibotti or a more comprehensive assessment pursuant to s. 30 of the Children’s Law Reform ActIt is typically short and the time from engagement of the interviewer to delivery of a report is very brief. Typically, no contextual information is gathered and no recommendations are made. A VOCR’s practical benefit is giving a child a chance to be heard. Not uncommonly, recourse to a VOCR is challenged because one or both parents are concerned that it can be used by a parent to manipulate a child’s views, that it has potential to alienate a child and further the goals of the alienator parentGajda v Canepa, 2018 ONSC 5154 at para. 23. Where there is an imbalance in a child’s relationship with its parents or where one or both of the parents decline to acknowledge that the other is capable of identifying and responding to children’s needs, caution must be exercised in giving undue weight to the report.”

         A.E. v. A.B., 2021 ONSC 7302 (CanLII) at 64