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Alberta - Re JNDW (1990), 104 AR 48 (PC)

Re JNDW (1990), 104 AR 48 (PC) (Fitch J.)

Permanent guardianship application of 2-year old child – returned on supervision order and apprehended again – mother with substance abuse and mental health issues – child with developmental deficits and possible FAS – special needs requires higher standard of care – given age of child no prospect of return within a reasonable time – permanent order