Canadian Supreme Court: Office of the Children’s Lawyer v Balev, 2018 SCC 16

Successful appeal against return using 13(2) – child’s objection – and a ‘hybrid approach to habitual residence: ‘Under the hybrid approach, a child’s habitual residence can change while he or she is staying with one parent under the time‑limited consent of the other. The application judge considers the intention of the parents that the move would be temporary, and the reasons for that agreement but also considers all other evidence relevant to the child’s habitual residence.’