What is the standard of review applied in interim custody and access cases?

Mr. Justice Meiklem in a considered decision, Thibeault v. Ravelo, [1999] B.C.J. No. 1457 (S.C.), provides guidance as to the standard of review to be applied in interim custody and access cases. He concluded that in some cases, interim dispositions are vital to the disposition of the case. He stated at para. 15: In my view there can be no absolute rule that Master's decisions on interim custody and access matters are purely interlocutory and should not be interfered with on appeal unless established to be clearly wrong. Interim rulings concerning custody of children or access to children must be examined on a case-by-case basis to determine if the interim ruling will likely have a direct bearing on the disposition of those issues at trial, bearing in mind the specific issues and the length of time the interim ruling will be in place.