“The father also relies on Bouchard v. Sgovio, 2021 ONCA 709 (Ont.C.A.), where the court dismissed an appeal from an order granting the mother temporary custody of two children until further order of the court to permit the mother to enroll the children in the “Family Bridges” program, said order being based on the father’s conduct that included failure to participate in court-ordered parenting time with the mother and efforts to sabotage or actively undermine court-ordered therapy; at the time of the appeal decision the children were ages 12 and 15.
Before a court can find parental alienation, it is necessary to examine whether there has been “realistic estrangement” and whether a rejected parent’s behaviour is a contributing factor to a damaged parent-child relationship; even where a favoured parent engages in problematic behaviour, a child may not be “alienated” where there are independent reasons to explain the child’s feelings. The foregoing is set out in the following trial decisions relied on by the OCL: W.A.C. v. C.V.F., 2022 ONSC 2539 (Ont.S.C.J.) at para. 509; and Supple (Cashman) v. Cashman, 2014 ONSC 3581 (Ont.S.C.J.) at paras. 3, 18, 23.”
C.T. v. M.M.M., 2023 ONSC 7247 (CanLII) at 81-82