text: All of the aforementioned claims are based squarely within the wording of the Family Law Act. However, it should be noted that section 61(2) uses the words “may include” before listing the types of claims that can be pursued. This indicates that other claims for damages not listed may actually fall within the parameters of the section. Historically, the Ontario Court of Appeal has endorsed a robust interpretation of this section so to not limit its applicability; for this reason, section 61 has been relied upon to recover transportation costs family members have incurred to transport their injured loved ones, as well as legal expenses incurred by family members to participate in an Inquest following the death of an incarcerated family member. What is clear from these examples is that the potential for recovery for family members pursuant to section 61 is only limited by the creativity and advocacy of your lawyer.