This scenario of one marriage partner converting to become a Jehovah’s Witness and then marital conflict and divorce ensues has also been demonstrated in Canadian courts. The marital conflict is even stronger where both parties were Jehovah’s Witnesses and one of the parties changes their beliefs.

[7] The word ‘tolerance’ does not appear to be in the mother’s vocabulary. She admits that religion was the primary cause of the marriage failure.

– Villa v. Villa, 1993 CanLII 14784 (MB QB), http://canlii.ca/t/g9gx9

[11] I would characterize the parties’ relationship as one of high conflict. The claimant is a practising Jehovah’s Witness and his religious beliefs led to criticism of the respondent for being a lapsed Jehovah’s Witness.

– P.H. v. K.H., 2016 BCSC 56 (CanLII), http://canlii.ca/t/gmzhv

[5] 4. That the respondent converted to Jehovah Witness in or about 1980-81, a factor which lead to the breakup of our marriage.

– Fougere v. Fougere, 1986 CanLII 5871 (NB QB), http://canlii.ca/t/gbfj8

[page 296] The defendant, on the other hand, after inquiring into several sources of spiritual renewal, including Roman Catholicism, actively embraced the doctrines of the Jehovah’s Witnesses. Inevitably, this disparity of faiths brought about internal disruption and ultimately the parties went their separate ways.

– Sullivan v. Fox, 1984 CanLII 4805 (PE SCTD), http://canlii.ca/t/gbjbb

[6] Mr. A. attributes the beginning of the changes in their harmonious relationship to the influence of a local female friend of Ms. L.’s, who introduced Ms. L. to the beliefs of Jehovah’s Witnesses during 1997. Ms. L. gradually became more and more interested in bible study and the beliefs of Jehovah’s Witnesses, and Mr. A. perceived that as a diversion from their way of life and a threat to their relationship. Conflicts arose, and Ms. L. took a much more assertive stand as time went on.

– A. v. A., 2003 BCSC 1593 (CanLII), http://canlii.ca/t/4r14

“There are also notations that his wife became a Jehovah’s Witness which caused problems.”

– 100003137049 (Re), 2018 CanLII 83095 (CA VRAB), http://canlii.ca/t/httkm

[page 700] In his absence, his wife had changed her religious affiliation and had become a very zealous member of Jehovah’s Witnesses. He was still a staunch Anglican. Prior to his enlistment in the army he and his wife were adherents of the Anglican faith and the children were being reared in that faith. When he returned home he found that at least the two eldest of the children who were living at home very strongly sided with the mother in religious matters and the co-operation which the mother had originally given him in religious matters had entirely disappeared. Three of the four children who by this time had left home had changed their religious affiliations to Jehovah’s Witnesses and were, like the mother, militantly zealous in their new beliefs. Whatever authority the father originally had in his own home in matters of religion had shrunk almost to the vanishing-point. Some of the younger children went to Sunday School with the father on occasions, but after 6 months or so they refused to go at all. Where there had once been reasonable harmony in this family unit there was now disharmony. For all this he blamed his wife and more particularly did he blame the members of Jehovah’s Witnesses whom he regarded as having invaded his home and sowed the seeds of this new belief in his absence.

– Re Bennett Infants, 1952 CanLII 293 (ON CA), http://canlii.ca/t/gwckj

[7] Le père ne semble pas favorable à un retour au sein des témoins de Jéhovah tel qu’entrepris par la mère. De son côté, il a abandonné les témoins de Jéhovah. Il s’en trouve excommunié selon la mère. Une personne qui agit ainsi serait qualifiée d’exclue. X appelle son père ainsi : « l’exclu ».

– Droit de la famille — 092329, 2009 QCCS 4363 (CanLII), http://canlii.ca/t/25wf0

“There is no question that Bethany’s illness led Mr. Hughes to seriously question and ultimately reject the teaching of his and his family’s religion, and that he paid a high price for that moral and religious decision, including the shunning by the Jehovah Witness congregation and alienation from his wife and children,” Court of Queen’s Bench Justice Rosemary Nation wrote in her 2003 divorce settlement decision.

– Appeal – Hughes v Hughes, 2013 ABCA 131 (CanLII), http://canlii.ca/t/fx2j3

Harvey v. Lapointe, 1988 CanLII 8787 (QC CS), http://canlii.ca/t/g9m67 – cites: Moseley v. Moseley, 1989 CanLII 7260 (AB PC), http://canlii.ca/t/gb18j – [page 758] The children were involved in Jehovah’s Witness religious activities including door-to-door canvassing, and indeed the mother’s involvement in this religion and her decision to inculcate the teachings of her faith was a major cause of the separation.

[page 419] Le défendeur pratique sa nouvelle foi depuis quelques années. Apparemment, ce fut le motif de la séparation des parties.

– H.(N.) v. P.(C.), 1988 CanLII 8798 (QC CS), http://canlii.ca/t/gc3w1

1. The Child(ren)’s Life Growing Up As a Jehovah’s Witness

Although section 3 – The Harms of Jehovah’s Organizations discloses much of life as a Jehovah’s Witness child, the courts also provide a glimpse into this aspect.

The judge pointed out that, on the evidence, the main problem for the child resulted from the appellant’s religious fanaticism and that such fanaticism disturbed the child.

– P. (D.) v. S. (C.), 1993 CanLII 35 (SCC), [1993] 4 SCR 141, http://canlii.ca/t/1frwx

[78] A. states that she was able to get J. to school. She states that K.(1) and V. started to refuse to go to school because they both suffered from anxiety and bullying. A. explained that the bullying began years prior and was due to their participation, at that time, in the Jehovah Witness faith. She states that the girls spoke openly about all non-believers going to die and that this did not make them popular. They also could not participate in “normal” childhood activities such as birthday parties, Halloween, and Christmas.

[82] A. was sexually abused by a member of the Jehovah’s Witness faith when she was a young child. The boy who assaulted her was age 10 and she was age 4 and the abuse continued for approximately 6 years.

[89] A. has left the Jehovah Witness faith. Ms. T. and her husband are active in the faith. A. has made it clear that she does not want K.(2) to be exposed to that faith.”

– British Columbia (Director of Child, Family and Community Services) v. A.B., 2019 BCPC 35 (CanLII), http://canlii.ca/t/hz4cs

[page 298] It was quite clear from his evidence that the children of adherents are circumscribed by severe limitations with respect to the activities in which they are permitted to engage with their peers, whether at school, on the playing field, or in youth groups. Public participation in many of those secular activities is frowned upon, if not actively prohibited. I think it can be correctly stated that the adherence to the principles of the prevailing dogma sets those children apart from those of the mainstream.

– Sullivan v. Fox, 1984 CanLII 4805 (PE SCTD), http://canlii.ca/t/gbjbb

[page 360] When I made the original order it was with the naive expectation that there existed sufficient good will and co-operation between the parents, insofar as the best interests of the children were concerned, that all could live comfortably within the broad framework of the order. This did not prove to be the situation.

– Sullivan v. Fox, 1985 CanLII 5132 (PE SCTD), http://canlii.ca/t/gbr63

[63] The subject of soccer and the father’s views on it consumed considerable trial time. The father believes that, based on the tenets of the Jehovah’s Witnesses’ faith, J. should not be participating in competitive sports. However, he does not wish to be seen as not supporting his son in an activity he clearly enjoys. The father described the moral dilemma this poses for him. The father, somewhat reluctantly, has attended some of J.’s more recent soccer games. However, on occasion, J. has missed Saturday soccer games when in his father’s care.

– A.D.W. v B.J.W., 2018 BCSC 1179 (CanLII), http://canlii.ca/t/ht0k7

[35] On the other hand, the co-parenting difficulties have grown since C.H. has started school. He is exhibiting behaviour problems in school.

[38] The respondent cannot register C.H. in any team sport or extracurricular activity that falls on a weekend because the claimant will not take him to these activities.

– P.H. v. K.H., 2016 BCSC 56 (CanLII), http://canlii.ca/t/gmzhv

[33] It is considered that the mother’s view that J.’s religious preferences will become his own voluntary choice, is somewhat naïve if she is to be the primary custodial parent. That is, if J. continues to attend religious meetings and missionary outings, as he is already doing, this is bound to become a formidable influence on his emotional and intellectual development, as it will be one of the most dominant influences on his life.

[45] I tend to agree with the view that taking a child as young as two on door-to-door missionary service is ostensibly exploitive, and more in the best interests of the church than of the child…We would not be approving of the vacuum cleaner salesman cited by way of analogy at trial who had his two year old son or four year old son in tow.”

– A. v. A., 2003 BCSC 1593 (CanLII), http://canlii.ca/t/4r14

I would remind the parties in the words of Wood, J.A. in Young at P. 34 that: “Obviously, if the exercise by each of (the parents) their individual freedom of religion, caused or threatened the probability of real psychological or physical harm to their children, state sanctioned intervention to preserve those interests would be justified under s. 1 of the Charter.

– James v. Page, 1990 CanLII 2025 (BC SC), http://canlii.ca/t/1dv27

[53] Both S. and K. indicated serious unhappiness with their present situation, and a firm desire to live with their father. They find their present situation isolating and frustrating. Ms. N.’s adherence to her religious precepts are perceived by the children to place many unreasonable limitations on their friendships and activities. They feel pressured. K. is not permitted to play on organized, competitive sports teams, because competitive sports are disapproved of by Jehovah’s Witnesses. The children are permitted regular interaction only with adults and other children who are also Jehovah’s Witnesses. The children perceive that their mother does not approve of friendships with other children.

[55] S. also told Dr. Elterman that she wants to live with her father so that she can choose her friends and participate in school and after school activities. S. testified that although she has many friends at school, after school she is not allowed to play with friends who are not Jehovah’s Witnesses.

[65] K. continues to struggle socially, academically and emotionally. He is lonely. K. told Dr. Elterman he cries himself to sleep, and his mother admits this is so. K. has few friends his own age, and appears to lack the social skills at present that would make it easy for him to remedy this, even if his mother did not have decided views on appropriate companions for her children. While K.’s present school is an improvement over the isolation of home-schooling, the Learning Outreach Centre offers him limited opportunities for interaction with his age-peers, and no opportunity to participate in school sports teams or other group activities.

[68] Ms. N. also seems to hold very conservative views about appropriate sexual behavior between married adults and regards behavior such as masturbation to be deviant, and a possible indication of aberrant sexual interests.

[74] Although Ms. N. said that she did not restrict the children’s out-of-school friendships to members of the Jehovah’s Witnesses only, she could give only one example of an occasion on which one of the children had been allowed to play with a child who was not a Jehovah’s Witness – an occasion in June 1997, when she took S. to the home of a child for one visit.”

– S.D.N. v. M.D.N., 1997 CanLII 12618 (BC SC), http://canlii.ca/t/1wrch

Mother presented extensive evidence that the conflicting practices and rules in each household that stemmed from her and father’s disparate religious beliefs were causing Hannah and Hillary to experience extreme confusion and anxiety. For instance, Hannah’s teachers testified to Hannah’s struggle over participation in birthday and holiday activities at school, a practice that father’s religion, that of the Jehovah’s Witnesses, prohibits, but a practice that mother encouraged. Hannah’s third grade teacher testified to an incident in which father came to the school one day to discuss Hannah’s participation in such activities, indicating that he did not want Hannah participating and that the teacher should inform him if she was. The teacher went on to describe how Hannah confronted her the next day extremely upset, and told her that she had made the situation for Hannah worse, asking “why did you tell him?” (about Hannah occasionally participating). One of Hillary’s teachers testified that Hillary also appeared to struggle with the decision of whether to participate in birthday and holiday activities as well, but it was mostly confined to the beginning of the school year.

Mother also testified to symptoms of anxiety in both girls – Hannah experiencing nightmares, stomach aches, and a constricted throat; Hillary being very clingy and sucking her thumb. Hannah’s pediatrician had ruled out organic causes for her physical symptoms after seeing her on two occasions, and indicated in her testimony that she thought the symptoms had been caused by anxiety. She stated that she recommended counseling to mother for Hannah. The counselor who had been seeing Hannah at mother’s request – prior to her termination by father – testified that she considered Hannah to be suffering from anxiety and attributed it to Hannah’s conflicted situation, including the conflict of mother and father’s religious beliefs and practices.

Based on this and other evidence, the court made specific findings regarding the negative effects on the children of mother’s and father’s differing sets of beliefs, including the children’s feelings of disloyalty, guilt, confusion, and anxiety. Thus, not only was evidence of harm presented, but the trial court made specific findings that the conflicting beliefs and practices in each household were having a palpable negative impact on the children, and would continue to do so.

– Meyer v. Meyer (2000-420); 173 Vt. 195; 789 A.2d 921

Even Jehovah’s Witness grandparents will take great efforts to indoctrinate their grandchildren against the wishes of the non-Jehovah’s Witness parent.

[22] The grandparents adhere to the Jehovah s Witness faith. They are actively involved in their faith and believe that not to practise it while the children visit them would amount to not portraying themselves as they really are. Both grandparents say they will not have the children accompany them while they are evangelizing. However, they have friends of the same faith who visit them and converse about their faith and the Bible and the grandparents want to be free to have these friends to their home while the children are present. They would also like to take the children, as they have in the past, to their place of worship, the Kingdom Hall.

[24] Tracy Ewanchuk was raised in an agnostic household and does not attend church. She testified that she disagrees with many of the practices of the Jehovah s Witness faith and is strongly opposed to the children being involved in it. She testified that the exposure thus far has caused Asia to question some of the things she has told the girls.

– Ewanchuk v Ewanchuk, 2002 NWTSC 67 (CanLII), http://canlii.ca/t/5gt8

[9] The most contentious issue between the parties is over whether or not A.W. should continue to be exposed to the Jehovah’s Witness faith and whether the applicants should be allowed to take her to services at the Kingdom Hall.

[10] From the time A.W. was a baby, the applicants took her to services at the Kingdom Hall. They did not ask the respondent for her permission. The respondent was not happy about the applicants taking A.W. to their church but she did not tell the applicants about her views at first.

[11] In December of 2013 the respondent told the applicants that she did not want A.W. attending services at the Kingdom Hall anymore. The timing of the applicants’ contact was changed so that the applicants did not see A.W. on the days that they regularly attended services.

[12] In March 2014 the respondent learned from A.W. that A.R. had taken her to a service at Kingdom Hall. A.R.’s explanation for defying M.W.’s wishes was twofold. First, she stated that the then barely three year old A.W. had “begged to go to Kingdom Hall”. Second, A.R. stated that M.W. never explained her reasons for not wanting A.W. to attend services at Kingdom Hall.

[13] AW told her mother about her attendance at Kingdom Hall. The following exchange of text messages then took place between M.W. and A.R.:

M.W: “Did you take [A.W.] to service yesterday?”

“?”

A.R.: “Sorry. My phone was on silent. Just saw ur txt.”

You don’t need to ask me. You can ask [A.W.] and she’ll tell you.”

M.W.: “She did tell me you did. And I don’t appreciate you going behind my back after I had said I didn’t want her going there anymore. So I’ll be keeping her”

“this Sunday.

A.R. When u said that I did not agree with you. And she asked me to take her to the Kingdom Hall. She said she misses the Kingdom Hall.

[14] M.W. stopped allowing the applicants to see A.W. on Sundays as a result of them not respecting her wishes about A.W. attending services at the Kingdom Hall.

[15] In April of 2014 A.R. drove A.W. to the Kingdom Hall. Once again, M.W. learned of the A.R.’s actions from the child. Once again, A.R. justified her actions by saying that is what the child wanted.

[16] M.W. then advised the applicants that they could no longer have overnight visits and that future visits would be at M.W.’s home.

[17] The applicants did not react well to M.W.’s decisions. After both the March and April incidents A.R. sent texts to M.W. referring to the possibility that A.W. would “hate” M.W. when A.W. grew up. M.W. explained to the applicants that she, as A.W.’s mother, had the right to decide if and when A.W. was exposed to religious teachings. This explanation fell on deaf ears.

[21] During one of these visits A.W. watched, at least for a short time, a Jehovah’s Witness video on A.R.’s laptop. M.W. was not pleased that A.R. had once again ignored M.W.’s decision not to expose A.W. to religious teachings. A.R.’s explanation is that it was A.W. who pushed the play icon and that A.W.’s brother had taken the laptop away before A.R. could stop the video. A.R. testified that she was showing A.W. pictures of the times that A.W. was at the applicants’ home. There was no explanation of why the video was open on the laptop so that all A.W. had to do was enter one command.

[27] The applicants say that if a court order forbids them from taking A.W. to the Kingdom Hall they will obey that order and that they would also obey an order not to initiate discussions on religion. The applicants were frank in conceding that it would be very hard, if not impossible, for them to comply with an order banning them from expressing their religious beliefs in response to questions from A.W.

[28] The applicants view M.W.’s decisions on A.W.’s exposure to the Jehovah’s Witness faith as a reflection of her prejudice. They blame M.W. for causing confusion in the child’s life and are convinced that M.W. is trying to punish them.

[29] The applicants are wrong to blame M.W. for the diminution in the time they spend with A.W. The applicants have knowingly defied M.W.’s wishes on several occasions. Their explanations include that unless they agree with M.W. they do not have to do as she wants and that they can ignore M.W.’s wishes if A.W., a very young child, expresses a contrary view.

[39] Balancing all of the factors set out, and having considered all of the evidence presented, I am concerned that the applicants’ demonstrated inability to respect and comply with M.W.’s decisions on religion will continue to cause conflict. It is not in A.W.’s best interests to be exposed to that conflict.

[40] There are many people with strongly held religious views that do not discuss those views in front of others, and specifically not in front of other people’s children. As noted above, the applicants do not appear to be capable of not exposing A.W. to their religious beliefs. Unless and until the applicants satisfy M.W. or the court that they can respect and comply with M.W.’s parental decisions on religion, their time with A.W. must be supervised and limited.

– A.R. and B.R. v. M.W. and L.R., 2015 BCPC 285 (CanLII), http://canlii.ca/t/glnrj

1. Child Custody Disputes, Including Alienation

In addition to the above cases, the following cases show the harm caused by the Watch Tower Society’s policies.

[17] The parties were both raised as Jehovah’s Witnesses. There is no dispute that J. will be raised in the Jehovah’s Witness faith. However, the father was disfellowshipped in 2015 after he engaged in certain behaviour that was considered by the church elders to deviate from the accepted standards of conduct and morality endorsed by the faith. The father states that his goal is to be reinstated to the congregation and, although he is not part of the congregation, he attends his local Kingdom Hall meetings in furtherance of his efforts towards reinstatement. For the most part, his family members and friends who are Jehovah’s Witnesses have not associated with him since he was disfellowshipped. The father’s parents have never met his new wife.

– A.D.W. v B.J.W., 2018 BCSC 1179 (CanLII), http://canlii.ca/t/ht0k7

The concern of the mother is that if the father is permitted to take these two young children to Jehovah’s Witness Church proceedings, in the circumstance of her having been “disfellowshipped” by the church, that the effect would be to destroy the otherwise sound and loving relationship which they currently enjoy with their mother. Her concern is that by their attending the church, they will be further indoctrinated as to what their relationship should be to their “disfellowshipped” mother and that it is probable that this will have a serious detrimental effect on that relationship.

The mother, in her affidavit filed on December 9th, 1993, attaches as Exhibit C, a number of Jehovah’s Witness publi­cations which purport to advise and direct members as to how they should treat a former member who has been expelled. In an issue of the Jehovah’s Witness publication The Watchtower dated September 15th, 1981, there is an article entitled “Disfellow­shipping __ how to view it.” At page 24, the following appears: [quote]

On page 22 of this publication is a pictorial of a number of people sitting around a table with food on it at mealtime. Below it is the caption ” ‘Not even eating with’ a disfellowshiped person.”

[Family Court Counsellor report]

“I interviewed several members of the Jehovah’s Witnesses who assure me the children are instructed to respect and honour their mother as blood ties may never be severed. I am further assured by those members the children are not taught to shun or avoid their mother. Disfellowshipping is a means of disciplining a member of the Jehovah’s Witnesses who has seen fit to leave the group or denounce their teachings. No member of the group may have any contact with a person who has been disfellowshipped unless they happen to be elders. Should a person who has been disfellow­shipped speak to or attempt to contact any member the elders will contact that person with a view to determine whether or not that person wishes to return to become a practicing Jehovah’s Witness.

One Jehovah’s Witness expressed her anguish at the loss of a good friend Mary Hewitt but stated she must not have contact with that person because of the teachings of Jehovah and the group.

It is difficult to accept that two children as intelligent as Carinna and Adriel would not understand the concepts and practices of disfellowshipping and relate them to their mother’s situation. As one Witness described it, disfellowshipping in Mrs. Hewitt’s case relates to her immoral lifestyle. The confusion that would result with the teachings of Jehovah’s Witnesses to honour and respect your mother but have nothing to do with someone who has been disfellowshipped could create problems for Carinna and Adriel in the relationship with their mother.” [end quote of report]

My paramount duty is to consider what is in the best interests of the children. I have concluded that it is in their best interest to limit the activities of the father with these children during the access times. I am concerned about the potential for real harm to the children of interference with their relationship with their mother which may result from their attending, with or without their father, church services and other activities of that faith. The father shall be entitled to continue to teach these children in the Jehovah’s Witness faith but they shall not be allowed to attend Jehovah’s Witness church services, cere­monies or conferences, or to do door-to-door church communications or engage in like matters.

– Hewitt v. Hewitt, 1994 CanLII 3132 (BC SC), http://canlii.ca/t/1dn4h

[11] I would characterize the parties’ relationship as one of high conflict. The claimant is a practising Jehovah’s Witness and his religious beliefs led to criticism of the respondent for being a lapsed Jehovah’s Witness. The claimant taught his religious beliefs to C.H., who began treating the respondent with disrespect due to his father’s views of her as an adulterer. C.H. was taught that his mother would not be permitted to enter the House of God with him when she passed on. This caused the child great concern.

[15] It was also about this time that the respondent formally advised the claimant of her relationship with Mr. W. As she predicted, the claimant sent text messages to the respondent accusing her of living an immoral life and threatening to inform the church elders of her misconduct. At Christmas 2014, the claimant adopted Mr. W.’s Christian tradition of having a tree and presents from Santa Claus. In response, the claimant aggressively attacked her behaviour as immoral and sacrilegious. Unfortunately, the claimant shared these beliefs with C.H. who again criticized his mother’s actions.

[22] In July 2015, the respondent remarried and this exacerbated the conflict between her and the claimant. The claimant referred to Mr. W. as the respondent’s tenant or her lover and was quite disrespectful of him in his text messages. The respondent was also approached by elders from the Jehovah’s Witness church, likely based on information that they had received from the claimant about her adulterous lifestyle. The claimant also involved C.H. in the conflict by his instructions to C.H. that Mr. W. was not a real parent and thus C.H. could not be disciplined by his stepfather. The child’s attitude became very disrespectful of his stepfather and his mother due to the views about their lifestyle that the claimant had shared with him.

– P.H. v. K.H., 2016 BCSC 56 (CanLII), http://canlii.ca/t/gmzhv

I teach the children that this is a wicked system that we live in and those who don’t abide by what the bible has to say, that we should, the way we live, that those people won’t enter into the new system and that they’ll die. So Dave [the father] might perceive that as him being part of the wicked system, part of Satan’s system.

– Voortman v. Voortman, 1994 CanLII 1540 (ON CA), http://canlii.ca/t/6k1s

[5] The evidence here discloses that Mr. Fougere was aggressive in his efforts to persuade his children to his faith. Without Mrs. Fougere’s knowledge he took the children, while exercising access, to an out of town religious meeting and, as well, they accompanied him while canvassing on behalf of his Church on Saturday mornings. In addition he discussed his religion, sometimes in comparative terms, with his children. As a result of all this, Mrs. Fougere testified, she has difficulty in controlling her children after Mr. Fougere exercises access and that he creates confusion in her efforts to teach them her religion. She attributes both complaints to Mr. Fougere’s missionary zeal.

[8] The evidence disclosed that Mr. Fougere’s practice of his religious beliefs had the effect of eroding Mrs. Fougere’s authority and alienating the children from her. In addition they were confused by differing religious views causing them stress so that, as Mrs. Fougere put it, “they don’t know which way to turn.”

– Fougere v. Fougere, 1987 CanLII 7842 (NB CA), http://canlii.ca/t/gb8lw

[page 298] La preuve démontre amplement que le requérant, sans admet-tre être un membre des Témoins de Jéhovah, suit leur enseignment et étudie la Bible avec eux. Il admet que cette préoccupation religieuse ou morale occupe le premier rang dans sa vie et il désire transmettre ces notions à ses enfants. Il n’y a aucun doute que [S.] subi cette influence et parce que sa mère pratique la religion catholique il refuse de la visiter. L’intimée a relaté que durant leur vie commune le requérant est devenu obsédé par la doctrine prêchée par les Témoins de Jéhovah et tentait de l’imposer à la famille. Il est très agressif, autoritaire et n’accepte pas que son opinion sur divers sujets, soit contestée. Le requérant a témoigné et tant ses propos que son comporte-ment confirme qu’il est autoritaire et agressif et ses opinions religieuses ou morales sont fixes et omnipuissantes dans sa vie. Pour lui les fêtes religieuse catholiques, tel Noël, sont des fêtes païennes qu’il ne respecte pas. Il voudrait exercer des droits de visites ou de sorties de [J.] plus fréquents que ceux acceptés par l’intimée; cette dernière s’oppose parce que l’enfant est affectée par le comportement de son père.

– Droit de la Famille – 260, 1985 CanLII 5120 (QC CS), http://canlii.ca/t/gbszj

[8] Both parties were for a long period of time members of the Jehovah’s Witnesses religious sect from which the mother was, to use their expression, “disfellowshipped” after having been subjected to an inquisitorial ordeal by the elders of the sect. I am convinced that the father has in the past, and will in the future, use the alleged misconduct complained of and the beliefs of this sect to poison the mind of the oldest child against her mother.

[12] The access granted to the father as stated in this order is subject to the strict observance by him of the following terms and conditions concerning their religious education:

(a) He shall not take either of the children to any religious services without the express consent of the mother or take them to or enrol them in his religious camp meetings or similar gathering of his religious congregation.

(b) Neither he nor anyone associated with him or acting on his behalf shall use religious instruction in such a way as to turn the minds of the children against their mother or result in any further antagonism towards her in the guise of religion.

– Irmert v. Irmert, 1983 CanLII 1159 (AB QB), http://canlii.ca/t/29c5f

NOTE: The above Irmert case was appealed by Watch Tower Society elder and lawyer Glen How. – J.I. v. H.I., 1984 ABCA 286 (CanLII), http://canlii.ca/t/2dghq