In a child protection proceeding under the Child and Family Services Act, counsel for a sibling sought to add the sibling as a party to the proceeding concerning a younger child.
The court applied the criteria set out in Children’s Aid Society of London and Middlesex v. H.(S.) for adding a party in child protection litigation, including best interests of the child, potential delay, necessity for determining the issues, the ability to present a plan of care, and legal interest.
The court found the moving party had minimal contact with the child and no meaningful existing relationship beyond a biological connection.
Adding the sibling would likely delay the proceeding and was unnecessary for determining access issues that could be raised by existing parties.
The court concluded the criteria were not met and declined to add the sibling as a party.