About NAARC

The Narcissistic Abuse Awareness and Recovery Coalition (NAARC) is a federally registered Canadian nonprofit founded in 2024 and headquartered in Hamilton, Ontario. NAARC represents approximately 400,000 members worldwide who have been directly affected by narcissistic abuse, coercive control, and related forms of psychological exploitation — including within the family court system.

NAARC's mandate is behavioral-science-based and gender-neutral. We recognize that coercive control and narcissistic abuse are functions of personality and psychology, not gender. Our advocacy is grounded in peer-reviewed research, clinical frameworks, and lived experience across all demographics. We do not advocate for any gender — we advocate for evidentiary integrity, equal protection, and the best interests of children.

NAARC actively promotes public and professional education, and identifies emerging research in the fields of coercive control, narcissistic abuse, moral injury, and institutional betrayal. Current research priorities include the intersection of family court proceedings and male suicide risk, the long-term developmental effects of parental alienation on children, and the application of behavioral-science frameworks to family law policy.

NAARC has standing to submit this brief as an organization with direct, ongoing engagement with survivors of family court-related coercive control, parental alienation, and institutional betrayal across Canadian and international jurisdictions.

Executive Summary

Three arguments. One constitutional risk.

NAARC does not oppose child protection. We oppose legislation that undermines it.

Bill C-223 fails its own legal standard. By restricting judicial recognition of parental alienation, the legislation increases the risk that courts will misidentify the protective parent as the problem — producing the precise outcome it claims to prevent. Further, C-223 encodes gender asymmetry into family law under the appearance of child protection. Legislation that renders these behaviors legally invisible when directed at one class of victim does not protect children — it selectively protects some children's parents while leaving others without remedy.

1. C-223 Is Contrary to BIOC — On Its Own Terms

The governing standard in Canadian family law is the Best Interests of the Child. C-223's restriction on parental alienation evidence does not meet this standard. It violates it. The bill's own preamble acknowledges concern that alienation claims "may be used in cases of domestic abuse or child sexual assault to support the accused parent." But the legislative response — categorical exclusion — eliminates the evidentiary framework for all cases, including those where alienation is the primary harm and no family violence is alleged or established.

Bill C-223 makes this explicit in its operative text. New subsection 16(3.1) provides that courts "shall not take into consideration any allegation that a spouse has, or is likely to, through deliberate manipulation, persuade or encourage a child to become estranged from or resist contact with the other spouse." The limited exception in s.16(3.2) permits such evidence only where the alleging parent has already been found to have engaged in family violence — and only if the evidence is "not presented to support an allegation of conduct described in subsection (3.1)."

This is a circular evidentiary trap. The evidence is nominally available but functionally prohibited: it can only be admitted after a family violence finding, and cannot be used for its primary purpose. A parent who has not been found violent — which describes most protective parents in alienation cases — has no evidentiary pathway at all.

The alienating parent frequently presents as the more distressed, more engaged, and more ostensibly "concerned" party — because manufactured conflict and emotional escalation are the mechanism of alienation itself. A court stripped of the evidentiary framework to interpret that presentation has no means to distinguish protective concern from tactical performance. The protective parent is then structurally disadvantaged by the legislation nominally designed to protect their child.

Restricting evidence of alienation does not eliminate alienation. It eliminates the remedy.

2. Scientific Consensus and Standard of Care

Proponents of C-223 frequently assert there is "no scientific consensus" on parental alienation. This assertion is factually incorrect and should not be permitted to anchor legislative policy.

The ICD-11 (World Health Organization, 2022) includes caregiver-child relationship problems as a recognized diagnostic category. The American Professional Society on the Abuse of Children (APSAC) has explicitly characterized systematic alienating behavior as a form of child psychological abuse. The DSM-5 recognizes "parent-child relational problem" as a clinically significant condition. Warshak's 2015 consensus report — endorsed by 110 researchers and clinicians across 35 countries — concluded that alienation constitutes a serious mental health problem requiring early intervention.⁴

The political controversy surrounding the label "parental alienation" does not eliminate the clinical reality of the conduct. Renaming the behavior does not change its effects. The committee is not being asked to endorse a diagnostic label — it is being asked to preserve the evidentiary framework that allows judges to assess documented behavioral patterns. Eliminating that framework because the terminology is contested is legislating ignorance into child welfare proceedings.

If the conduct described in C-223's preamble — a parent deliberately manipulating a child to resist contact with the other parent — is real, then evidence of it must be admissible. If it is not real, the bill's own preamble is incoherent. C-223 cannot have it both ways.

3. The Flaw of Ideological Exclusion

C-223 claims gender neutrality while operationally encoding gender asymmetry. This is its central contradiction.

Narcissistic abuse — characterized by entitlement, lack of empathy, and the systematic erosion of a target's legal, social, and psychological standing — is a behavioral profile, not a gendered one. Parental alienation is a documented behavioral outcome of high-conflict, coercive personality dynamics. It is perpetrated and experienced across all genders.

Legislation that suppresses the vocabulary required to describe these behaviors provides a state-sanctioned shield to high-conflict perpetrators regardless of their gender — while ensuring their targets, disproportionately but not exclusively male, have no recognized legal language to describe what is being done to them or their children.

The same coercive control behavior, directed at a female victim, would be fully cognizable under the law. Directed at a male victim through the mechanism of alienation, it becomes legally invisible. That asymmetry is not child protection. It is selective protection by gender of victim.

Peer-reviewed research supports this pattern. A 2024 study of Ontario family court costs decisions found that while men were somewhat more likely to have engaged in litigation abuse overall (53% vs 47%), men were more likely to be victims of litigation abuse in cases focused on parenting — precisely the kind of case-specific, gender-differentiated pattern that a blanket evidentiary exclusion would render legally invisible (Bala, Benedetti & Franzmann, 2024).³

Professor Nicholas Bala's 2024 study analyzing 411 Ontario family court costs decisions over a three-year period — of which 222 (54%) involved judicial findings of litigation abuse² — yields three findings directly relevant to C-223:

• While men were somewhat more likely to be perpetrators overall (53% vs 47%), in parenting-specific disputes mothers were perpetrators of litigation abuse in 60% of cases.
• In all 9 cases where a judge made a finding of parental alienation, the mother was the perpetrator. These are judicial findings of fact — not allegations. C-223's restriction on alienation evidence would render this judicially confirmed pattern legally invisible.
• Self-represented litigants — disproportionately fathers, less likely to qualify for Legal Aid — engaged in litigation abuse at roughly twice the rate of represented parties, compounding their structural disadvantage where alienation evidence is suppressed.

These are not advocacy claims. They are findings of Ontario judges, published in a peer-reviewed journal. A law that restricts the evidentiary framework for identifying precisely the conduct these judges documented is not protecting children — it is protecting perpetrators.

Under C-223's subsection 16(3.2), the alienation evidence Ontario judges relied upon could only be admitted if the perpetrator had already been found to have engaged in family violence — a condition that, by definition, cannot be met before the evidence is heard. The bill requires a finding to admit the evidence necessary to make the finding.

This circularity is compounded by what may be termed the Record Fallacy. C-223 treats a prior finding of family violence as a neutral, available metric — but it is not. Reporting rates are not a proxy for the prevalence of behavior. A law that triggers evidentiary rights based on prior records codifies existing systemic bias — it grants an evidentiary advantage to the party who engaged the system first, rather than the party who is behaving protectively. The protective parent who did not make prior reports is structurally penalized for their restraint.

The Mirror Test — Section 15 Charter Implications

The Committee should apply a simple equality test: if a female victim were experiencing identical Identity Annihilation and Institutional Betrayal — and a law blocked her evidence — would this Committee find that acceptable? The answer is no. By that same standard, C-223's gender-asymmetric evidentiary exclusion constitutes a prima facie violation of Section 15 of the Canadian Charter of Rights and Freedoms. The Committee should require Charter compliance analysis before passage.

4. Moral Injury and Identity Annihilation

When the legal system refuses to recognize psychological warfare, it does not remain neutral. It becomes a participant — with measurable downstream effects on mental health outcomes, including suicide risk.

Being compelled to watch the systematic erasure of one's relationship with a child — while the legal system categorizes the perpetrator's conduct as protected parenting — constitutes a Potentially Morally Injurious Event (PMIE) of the highest order. The targeted parent is not merely losing a legal argument. They are experiencing state-endorsed invalidation of their parental existence.

Left unaddressed and compounded across years of litigation, this produces Identity Annihilation: the neutralization of a parent's legal, social, and psychological standing by institutional refusal to intervene. The child suffers a parallel harm — the enforced removal of a protective relationship, rationalized by a framework that cannot see the mechanism producing it.

The psychological literature documents that parental alienation causes irreversible harm to children, including impaired attachment, depression, anxiety, substance abuse, and damaged capacity for relationships persisting into adulthood. Warshak's 2015 consensus report concluded that early intervention is critical to mitigating long-term harm.⁴ Baker's longitudinal research documents low self-esteem, chronic depression, and impaired relational functioning as consistent long-term outcomes.⁵

The developmental window argument is decisive for BIOC purposes: alienation operates during critical periods of attachment formation. Delayed intervention is not procedurally neutral — it is developmentally compounding. Every month the evidentiary framework is unavailable is a month of irreversible harm to the child.

The clinical literature on moral injury documents a direct pathway from Potentially Morally Injurious Events to suicidal ideation, independent of PTSD (Bryan et al., 2013).⁶ When the injurious event is state-sanctioned — when the institution designed to protect instead participates in the harm — the moral injury is compounded by institutional betrayal (Shay, 2014).⁷ The 3:1 male suicide ratio documented in Section 5 is the terminal outcome of this pathway, rendered invisible by the same data failure that C-223 would entrench.

5. Institutional Betrayal and Secondary Victimization

While proponents of Bill C-223 cite "secondary victimization" as a justification for restricting alienation evidence, NAARC contends that the legislation itself codifies a far more pervasive form of state-sponsored harm: Institutional Betrayal.

5.1 Defining the Mechanism of Harm

Drawing on the frameworks established by Shay (2014)⁷ and Smith & Freyd (2014),⁸ institutional betrayal occurs when an entity upon which a victim depends for safety — the Family Court — fails to prevent harm or actively penalizes the victim for seeking protection. By mandating that the judiciary ignore documented behavioral patterns of coercive control categorized as "alienation," the state effectively participates in the perpetrator's campaign to invalidate the victim's existence.

5.2 The "Invisible Victim" Paradox

Current legislative narratives surrounding C-223 rely on a rigid, gendered archetype of "victim" and "perpetrator." This creates a dangerous policy blind spot where male victims of coercive control are rendered legally invisible, as their experiences of psychological warfare are dismissed as "stereotypical" or "tactical" counter-claims.

5.3 Legislative Risk Assessment

The Committee should note that legislation which mandates judicial blindness to documented abuse patterns creates a foreseeable and measurable risk of harm. If C-223 passes and results in documented increases in male suicide, child trauma, or wrongful removal of protective parents — outcomes directly predictable from the evidentiary restrictions the bill imposes — the state faces systemic liability for legislating a foreseeable harm into the family justice system.

5.4 Mortality as a Metric of Systemic Failure

The refusal to acknowledge these victims is not a neutral legal act; it has terminal consequences. The documented 3:1 male suicide ratio (Statistics Canada, 2022)¹ suggests a direct correlation between Identity Annihilation — the state-endorsed erasure of a parent's role — and catastrophic psychological collapse. This is the measurable human cost of the evidentiary gap C-223 would permanently entrench.

5.5 Recommendation: Reversing the Victimization

To avoid becoming an instrument of secondary victimization, the Committee must ensure that:

1. The definition of "Family Violence" remains broad enough to capture the psychological exploitation of the parent-child bond.
2. The state recognizes that any parent, regardless of gender, can be the target of a Potentially Morally Injurious Event (PMIE) perpetrated through the misuse of the court's own evidentiary rules.

6. Statistical Integrity and the Suicide Gap

Current domestic violence metrics under GBA+ are structurally incomplete. They are designed primarily to identify female victimization, producing a significant dark figure of male victimization that renders downstream policy — including C-223 — built on partial data.

Approximately 3,800 men die by suicide annually in Canada (Statistics Canada, 2022), a figure roughly three times the female rate.¹ Because the intersection of domestic litigation, coercive control, and male suicide is not systematically tracked, the causal relationship remains unmeasured. The absence of measurement is not evidence of absence — it is a data collection failure with fatal consequences.

The committee must not allow the absence of data to be treated as confirmation that no problem exists. That absence is itself the problem C-223 should be addressing.

7. Recommendations for Amendment

1. Maintain Judicial Discretion — Ensure judges retain full authority to evaluate parental alienation evidence based on individual behavioral facts, free from categorical legislative exclusion.
2. Gender-Neutral Behavioral Intake — Mandate that all protective assessments are evaluated through a behavioral lens — specifically, documented patterns of coercive control — irrespective of which parent reports them. The identity of the complainant is not evidence. The pattern of behavior is.
3. Mandatory Mortality Review — Require that male suicides and MAID deaths where mental distress is a contributing factor be screened for histories of family court litigation and documented coercive control. This is a data integrity measure, not a gender advocacy measure.
4. BIOC Compliance Audit — Prior to passage, require the Minister of Justice to publish a statutory opinion demonstrating how C-223's evidentiary restrictions satisfy the Best Interests of the Child standard under existing Canadian family law.
5. Charter Compliance Review — Prior to passage, require an independent Section 15 Charter analysis confirming that C-223's evidentiary restrictions do not constitute discrimination on the basis of sex in the provision of legal remedy.

NAARC Declaration of Neutrality

• Abuse is Behavioral, Not Biological: We recognize that narcissistic abuse and coercive control are functions of personality and psychology, not gender.
• Evidentiary Integrity: Justice requires that all patterns of behavior be visible to the court. Suppressing any class of evidence based on the gender of the reporter or the perpetrator is a violation of fundamental justice.
• The Child's Right to Truth: Every child has a right to be protected from psychological manipulation, regardless of which parent is the source.
• Equality of Remedy: Every victim of coercive control or identity annihilation deserves a legal remedy that is not rationed by their sex or identity.

Appendix A: Behavioral Indicators of Alienation as Coercive Control

The following documents observable behaviors that constitute alienation as a subset of coercive control. The Committee is asked to assess the conduct, not the label.

If the Committee supports legislation against coercive control — and C-223's proponents assert that it does — it cannot logically support a provision that suppresses evidence of the behaviors listed above. These behaviors are coercive control.

Alienation is not a separate phenomenon requiring separate skepticism. It is coercive control directed at a child.

Nothing in this submission opposes the admission of evidence that a parent has engaged in family violence. We oppose only the categorical exclusion of evidence showing that a parent has systematically destroyed the child's relationship with the other parent without cause.