The appellant challenged a family law decision awarding sole custody, a defined access schedule, and retroactive child support.
The appeal was confined to access and retroactive support.
The court held that the trial judge applied the correct best-interests test under the Children’s Law Reform Act, was entitled to reject the OCL report as unreliable, and provided reasons that satisfied the appellate standard for adequacy.
The court further held that the trial judge properly applied the D.B.S. framework holistically and made no reviewable error in awarding retroactive child support to the child’s birth based on blameworthy conduct and the recipient’s delay explanations.
The appeal was dismissed, the trust funds were applied against arrears, and appeal costs were awarded to the respondent.