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In what sense does a judge take a parent as been hostile? If the judge finds you hostile towards the other parent would they take your child from you and give it to the other parent?
Judges acknowledge that parents can be loving to their child and at the same time hostile to the other parent – on that basis they would not just hand over the child.
They look at the status-quo (what has been the situation for a while) and what is in the best interest of the child.