This is why that in family law a final order, including a consent order, can only be varied if a “material change of circumstances” occurs after its making (See: M.K.R. v. J.A.R. at para. 16). And, a "material change in circumstances" for the purpose of the Divorce Act means "a change, such that, if known at the time, would likely have resulted in different terms" (Willick v. Willick, supra, at p. 688). b. The “provisional hearing”
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