parent’s unfitness in order for the guardianship to continue. Nor has the Legislature defined “fitness” for purposes of termination-of-guardianship cases. The law in these areas is unsettled and evolving. See Guardianship of Reena D., 163 N.H. 107, 35 A.3d 509, 514-15 (2011) (collecting cases and holding that where a guardianship was established by consent, for the court to order continuation of- the guardianship over the petitioning parent’s objection, the guardian must prove, by clear and convincing evidence, that the guardianship is “necessary to provide for the essential physical and safety needs of the minor” and that terminating it would “adversely affect the child’s psychological well-being” (quotation marks omitted)); see also Tourison v. Pepper, 51 A.3d 470, 473-74 (Del. 2012) (<HOLDING>); Boddie v. Daniels, 288 Ga. 143, 702 S.E.2d
holding that before a parents rights can be terminated the department must show by clear and convincing evidence that reunification with the parent poses a substantial risk of significant harm to the child holding that the guardianship must terminate unless the guardian proves by clear and convincing evidence that the petitioning parent is either unfit or has forfeited the right to custody holding that on a parents petition the guardianship must terminate unless the guardian proves by clear and convincing evidence that terminating the guardianship would result in physical or emotional harm to the child holding that despite the lack of a statutory requirement that severe child abuse be shown by clear and convincing evidence due to the consequences of such a finding the clear and convincing standard must be applied holding that fraud on the court must be supported by clear unequivocal and convincing evidence