E.A.B. v. K.J.B., 2017 BCSC 1167

The parties had an 11 year old son. The father had medical issues, and the parties disagreed about how that affected their son’s best interests. They also had long-standing communication problems. The wife applied for an order that a s. 211 report be prepared. The husband applied for an order for a Hear the Child report. Master Bouck described the differences between the two types of reports, noting that the question was whether a report about the child’s views alone was sufficient, or whether an assessment of the child’s needs and the parents’ abilities to meet those needs was necessary. She stated that on the authorities cited to her, the evidentiary threshold to be met to order a s. 211 report was low. On the evidence, Master Bouck ordered that a s. 211 report was needed.

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