“A parent seeking supervised parenting time for the other parent bears the burden of establishing that supervision is necessary: W.H.C. v. W.C.M.C., 2021 ONCJ 308, Klymenko v. Klymenko, 2020 ONSC 5451.
In Stec v. Blair, 2021 ONSC 6212, at paras. 22-24, Fowler Byrne J. reviewed the law related to supervised access and explained the reason that it is not automatically granted:
a. Supervised access is a great intrusion into the relationship between a child and parent and its continued imposition must be justified: Young v. Hanson, 2019 ONSC 1245, at para. 32, also cited in G. v. F., 2021 ONSC 1362 at para. 47.
b. The intrusion is less striking when supervision is by a family member in a home setting, but nonetheless, it is not a long-term solution. Supervised access is designed to provide a temporary and time-limited measure, to resolve a parental impasse over access, rather than provide a long [term] solution: M. (B.P.) v. M. (B.L.D.E.) 1992 CanLII 8642 ONCA, 97 D.L.R. (4th) 437, at para. 33 (Ont. C.A.).
c. The onus lies on the person seeking that parenting time be supervised, to show that such supervision is necessary. The greater the restriction on regular parenting time, the more important it is to show why the restriction is necessary: Liu v. Xie, 2021 ONSC 222, at para. 69, Docherty v. Catherwood, 2015 ONSC 5240, para. 38.
Supervised access “is beneficial for children who require gradual reintroduction to a parent, or whose safety requires it until such time as the parent is sufficiently rehabilitated and a child is no longer in danger or physical or emotional harm.” Najjardizaji v. Mehrjerdi, 2004 ONCJ 374 (CanLII), [2004] O.J. No. 5472 (OCJ).
The Courts have taken the view that because supervised access creates an artificial environment, it should not be ordered as a long-term arrangement: Hunt v. Hunt, 2023 ONSC 5411, at para. 43.”
Gerasimopoulos v. Sambirsky, 2024 ONSC 2368 (CanLII) at 25-28