The application therefore refers to both review and variation, which are two different things. A party seeking a variation under s. 17 of the Divorce Act must show a material change of circumstances. The nature of a review was defined in Leskun v. Leskun, 2006 SCC 25 at para. 37: 37 Review orders, where justified by genuine and material uncertainty at the time of the original trial, permit parties to bring a motion to alter support awards without having to demonstrate a material change in circumstances ...
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