“As Justice MacKinnon explained in Dunn v. Shaw, 2021 ONSC 8286 at paras. 20 to 22, deliberate and willful disobedience may be inferred if a party does not take concrete measures to apply normal parental authority to have the child comply with a parenting order. Parents cannot simply leave the decision about participating in parenting time up to the child. Instead, the parent has an obligation to do all they can to require the child to comply with the parenting order. Although the onus of proof beyond a reasonable doubt remains throughout on the moving party to the contempt motion, the other party has both a parenting responsibility and an evidentiary onus in responding to the contempt motion.”
