What is the test for a change in s. 17(4) of the Divorce Act?

Ontario, Canada


The following excerpt is from Smart v Smart, 2015 ONSC 4607 (CanLII):

The change referred to in s. 17(4) of the Divorce Act must be a material change. A material change means a change, which if known by the court at the time the order was made would have led to a different result: Willick v. Willick, 1994 CanLII 28 (SCC), [1994] S.C.J. No. 94.

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