What is the impact of self-help by the mother on the relationship between the father and the mother?

Ontario, Canada

The following excerpt is from Children's Aid Society of Toronto v. A.(S.), 2008 ONCJ 348 (CanLII):

[54] On the facts of this case, because the father lives in Montréal, his ability to build a strong and lasting bond with the child would be severely limited, perhaps entirely destroyed, were the court to give effect to the mother’s self-help. Doing so would enable the mother to create a status quo that could ultimately prove insurmountable in a subsequent custody trial. See the comments by Justice Sherr in Nyari v. Velasco, supra.

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