On an application for change to a custody, guardianship or access order there is a threshold requirement that there has been a material change in the circumstances affecting the child. If that threshold is met the court must embark on a fresh enquiry as to what is in the best interests of the child (Gordon v. Goetz, 1996 CanLII 191 (SCC), [1996] 2 S.C.R. 27).
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