Is a dependent spouse disentitled to support because they have not made efforts to become self-sufficient?

A dependent spouse is not disentitled to support because he or she does not make reasonable efforts to achieve self-sufficiency. Rather, a court should decide what employment is reasonably available to the dependent, attribute income appropriate to such employment, and reassess need and entitlement: see Bildy v. Bildy, supra. Alternatively, a court may award limited-term support to bring home to the dependent his/her obligation to make reasonable employment efforts: see Bildy v. Bildy, supra. At the expiry of the limited term, the onus is on the dependent to explain what efforts he/she has made and why support should continue if he/she is still under employed.