By Gene C. Colman ( July 11, 2022, 1:36 PM EDT) -- The Lawyer’s Daily recently published an article by Gary Joseph titled “The parental alienation dilemma” (June 14, 2022). Joseph postulated (correctly in my view) that if the February 2022 Ahluwalia v. Ahluwalia 2022 ONSC 1303 (Ahluwalia) decision is not varied on appeal, then we are likely to “see an increase in the claims for damages in family law disputes.” Joseph goes on to make a point that I myself have frequently made, to the effect that such decisions seem to fly in the face of the Supreme Court of Canada’s 1987 admonition (Frame v. Smith [1987] 2 S.C.R. 99) that in family law we do not assess damages for bad behaviour. The particular bad behaviour in that case as per paragraph 1 was “whether the appellant has a right of action against his former spouse and her present husband for interfering with his access to his children.” (By the way, according to CanLii, Frame v. Smith has been referenced in 1,025 cases.)...