May a non-custodial parent withhold his or her consent from the custodial parent’s efforts to obtain a passport for a child? Apparently not, especially if the need for the passport is for the child to visit an ailing grandparent.
In Snowden v. Snowden, a June 6, 2018 decision of the Appellate Division, Second Department,

Courts have recognized that it is in the best interests of a child to travel with a parent. A court may provide relief when one parent unreasonably withholds consent from the other parent to travel with a child and compel a divorced parent to cooperate with the other parent to secure a passport for a