Is there an inappropriate contempt motion under s. 17(5) of the Divorce Act?

Hefkey v. Hefkey, 2013 ONCA 44 provides an example of an inappropriate contempt motion. The moving party had an alternate remedy available, namely applying to vary the order in dispute. The court was critical of the choice of contempt, noting at para 4 that by seeking the relief he did, the father “sought to obtain indirectly what he chose not to seek directly: a variation of the disputed access order without the necessity of complying with s. 17(5) of the Divorce Act and meeting the evidentiary burden that applies on a variation application.”