Hefkey v. Hefkey, 2013 ONCA 44 holds:
 Moreover, in our view, the civil contempt remedy should not have been sought in the circumstances revealed by the record. The civil contempt remedy is one of last resort. It should not be sought or granted in family law cases where, as here, other adequate remedies are available to the allegedly aggrieved party. The courts have repeatedly stressed that great caution must be exercised when considering contempt motions in family law proceedings. Contempt findings in such cases should be made only sparingly and, as we have said, as a last resort "where conferences to try to resolve access problems or motions for enforcement have failed": see K.(L). v. G.(T),  W.D.F.L. 2571 (Ont. S.C.), at para. 58. See also Fisher v. Fisher,  O.J. No. 976 (S.C.); and Martinez v. Martinez,  O.J. No. 721 (Ont. Prov. Ct. (Fam. Div.)).