The parties separated and agreed the mother would have custody of their child, with the father having access rights.
The father, a Jehovah's Witness, used his access visits to indoctrinate the young child in his religion, which disturbed the child.
The mother sought to restrict his access.
The trial judge ordered that the father could teach his religion but not continually indoctrinate the child or take her to religious activities.
The Supreme Court of Canada upheld the order, confirming that the sole criterion for access disputes is the best interests of the child under art. 30 of the Civil Code of Lower Canada.
The Court held that the Charter does not apply to private family disputes and that the best interests standard is not unconstitutionally vague.
