On an amended temporary care motion in a child protection proceeding, the applicant society sought to vary an existing temporary order and place two children in its care pending trial.
The matter involved concerns about unexplained injuries to a child, repeated medical issues affecting the children, domestic violence between caregivers, and unsafe living conditions including drug paraphernalia and unsanitary housing.
The court considered the statutory framework under s. 51(6) of the Child and Family Services Act and rejected the necessity of a strict two‑stage “material change in circumstances” analysis, emphasizing the court’s ongoing obligation to assess risk of harm to the children.
The court found that the cumulative events and health concerns established that the children faced risks that could not be adequately addressed by supervision alone.
The temporary order was varied to place the twins in the society’s care, while another child remained in kinship placement with supervised parental access.
