What is the test for a variation in section 51(6) of the Child Protection Act?

[27] In Catholic Children’s Aid Society of Toronto v. L.F.[12] Katarynych J. stated that, as no statutory criteria are provided for section 51(6) variations, it was an exercise of judicial discretion, dependent of a variety of factors, all of which must be brought to bear on the evidence in the motion to vary. That judicial exercise was to ascertain whether “a variation of the ‘status quo’ makes common sense within the statutory scheme provided by Part III of the Act for child protection”. Katarynych J. then listed a number of factors she had considered in that case. Those factors were not the mandatory considerations listed in section 37(3) CFSA that relate to the best interests of a child. Many of the factors she took into account were temporal in nature.