The respondent mother brought a motion to vary the applicant's access to their seven-year-old child.
The respondent raised concerns that the applicant, who works in the sex trade, was not adhering to COVID-19 safety protocols with clients, thereby putting the child at risk.
The court found that the applicant failed to provide sufficient evidence of compliance with COVID-19 protocols, such as wearing masks and social distancing.
The court concluded that this constituted a material change in circumstances and temporarily suspended the applicant's physical access, replacing it with video access, until the applicant could provide an undertaking and a realistic proposal to comply with COVID-19 protocols.