ABSTRACT
Treyvaud J. also briefly considered whether he had the power directly to order the husband to grant a get, but declined to rule on such a "significant" matter without the opportunity to consider it at greater length.^
The significance of this case may be seen by comparing it with the only other reported decision of which the writer is aware, which links a get with access to children. In the American case of Pal v. Pal ? the husband sought to have the wife held in contempt for denying him his visitation or access rights, as agreed and incorporated into judgment in the civil divorce. Relief was denied because the husband had not performed his part of the agreement by cooperating in giving a get. This decision may be criticized on the ground that an excessively "contractual" approach is adopted to the question of the visitation rights. The question of the welfare or "best interests" of the children should properly take priority over the proprietorial or contractual interests of the parents,** even in the face of any "clean hands" argument which might be directed against the husband.
