The courts have recognized that a custodial parent has a responsibility to ensure that the non-custodial parent enjoys their access and relationship with the child.
Parental alienation can take many forms. It can manifest as the withholding parenting time, or thwarting communication with the child. There are other, more subtle and insidious forms. For example, constant criticism and badmouthing the non-custodial parent can also be considered a form of parental alienation.
In certain situations, the custodial parent can be deemed unfit on the basis of parental alienation, and the Court will direct a change custody.