“In Elisabeth’s evidence there was minimal recognition of the importance of Freya having a relationship with her father, Josiah.
Because of the timing of this motion, being brought immediately after the issuance of the application, there was no opportunity for Josiah to call evidence from an expert on child development and attachment, or to obtain a s. 30 assessment under the Children’s Law Reform Act, R.S.O. 1990, c. C.12, to assess Freya’s needs and the ability and willingness of Elisabeth and Josiah to satisfy those needs.
The courts however have recognized that children of Freya’s age [1 year, 9 months old] are at the attachment phase of development and that this is when children begin to form attachments to parents and caregivers. Children who are separated from one parent for extended periods of time at this age may not be capable of sustaining a meaningful relationship with that parent thereafter in addition to sustaining other adverse impacts. Young children, such as Freya, need frequent and meaningful contact with both parents to develop meaningful relationships with both: Prasad v. Lee (2008), 2008 CanLII 24545 (ON SC), 53 R.F.L. (6th) 194 (Ont. S.C.) at paras. 48-49.”