What is the test for making a post-Guidelines order for child support?

There is, however, continuing discretion where an applicant falls within the pre-condition in s. 14(b) - where it is sought to vary a post-Guidelines order which was not made in accordance with the table. In that case, “any change in the condition, means, needs or other circumstances of either spouse or of any child who is entitled to support” must be considered. The pre-guidelines case law may still be helpful here. For example, Willick v. Willick1, held that the change in circumstances had to be “material” in the sense that there had been a change in the relationship between the needs of the children and the means of the parents. If so, the court must re-assess the needs of the children in light of the change, taking into account the standard set by the means of the parents.