Family Lawyer in Mississauga

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Parental Alienation Syndrome (P.A.S.) is a term that was first coined by Dr Richard Gardner, a clinical professor of child psychiatry at Columbia University. Parental alienation is a child’s mental condition where s/he prefers one parent over the other without any justified reason. Inducing PAS in a child is a form of emotional abuse. In a way, it may be even more detrimental than physically and/or sexually abusing a child. Although both of these forms of abuse are abominations, they do not necessarily – although they certainly may – cause lifelong psychiatric problems: [Parental Alienation Syndrome 2nd Edition by Richard A. Gardner, M.D.]

Parental Alienation and Family Courts in Ontario

Ontario Courts have recognised parental alienation as a form of emotional abuse and strongly support that a change of custody may be an appropriate sanction when alienation is established.

In Malhotra v. Henhoeffer, 2018 ONSC 6472 at para 109, the court has listed the indicators of alienation and I shall mention a few of them in the following:

Child Behaviours:

  • View of parents one-sided, all good or all bad; idealizes one parent and devalues the other
  • Reactions and perceptions unjustified or disproportionate to parent’s behaviours
  • A stronger, but not necessarily healthy, psychological bond with an alienating parent than with a rejected parent
  • Anger at a rejected parent for abandonment; blames him/her for divorce
  • Stories are repetitive and lacking in detail and depth
  • Denial of hope for reconciliation; no acknowledgement of desire for reconciliation
  • Expresses worry for the preferred parent, desire to care for that parent; or, defensive denial that the child is indeed worried about a parent

Alienating Parent Behaviours:

  • Allows and insists that the child makes decisions about contact
  • Rarely talks about the other parent; uninterested in child’s time with other parents after contact; gives a cold shoulder, silent treatment, or is moody after child’s return from the visit.
  • Refusal to hear positive comments about rejected parent; quick to discount good times as trivial and unimportant
  • No encouragement of calls to other parents between visits; rationalizes that child does not ask
  • No concern for missed visits with other parents
  • Body language and non-verbal communication reveal a lack of interest, disdain and disapproval
  • Engages in an inquisition of a child after visits
  • Telephone messages, gifts and mail from other parents to the child are destroyed, ignored or passed on to the child with disdain
  • Does not believe that child has any need for a relationship with other parents
  • Exaggerates negative attributes of other parents, and omits anything positive
  • Delusional false statements repeated to the child; distorts history and other parent’s participation in the child’s life; claims another parent has totally changed since separation
  • Projection of own thoughts, feelings and behaviours onto the other parent
  • Does not correct child’s rude, defiant and/or omnipotent behaviour directed towards the other parent, but would never permit the child to do this with others
  • Denigrates and exaggerates flaws of rejected parent to child
  • Says other parent left “us”, divorced “us” and doesn’t love “us”
  • Over-involves child in adult matters and litigation
  • Overt and covert threats to withdraw love and affection from a child unless another parent is rejected
  • Extreme lack of courtesy to rejected parent
  • Relocation for minor reasons and with little concern for effects on the child


In Fielding v. Fielding, 2013 ONSC 5102, 39 R.F.L. 7th 59, Justice McKinnon heard expert evidence in the context of a trial in which parental alienation was alleged. According to the expert’s opinion, which was accepted by Justice Mackinnon, parental alienation is established if:

  • there was a prior positive relationship with the targeted parent;
  • there is an absence of abuse by the targeted parent;
  • the alienating parent uses many of the alienating strategies; and
  • the child exhibits most of the alienated child behaviours.


In Hazleton v. Forchuck, 2017 ONSC 2282, 93 R.F.L. 7th 254 at para. 75, Justice Gray stated:

Where parental alienation exists, it is manifestly important that steps be taken immediately. If they are not, the situation will only get worse. If the alienating parent continues to have unfettered access to the children, there is little doubt that the poisoning of the children’s minds will continue. At some point, the restoration of a relationship with the other parent becomes much more difficult, if not impossible”.

In Ma.M. v. A.W.M., 2019 ONSC 2128, the court, after finding the mother’s alienating behaviour, orders sole custody of the child to the father and orders that the mother shall not have any access to the child until further order of the court and the court further orders that the mother shall not communicate with the child in any way, directly or indirectly and she shall not attend the child’s school, or any place where she knows the child to be.


From Ma.M., we can easily assess that the court is taking parental alienation very seriously and taking firm actions by putting sanctions against the alienating parent, so it can be discouraged in society and to protect the child(ren) from mental abuse.