What is the test for post-secondary education to determine whether a child is still a child of the marriage?

The court in Gasparini v. Gasparini, 2014 BCSC 1465 summarized the principles animating post-secondary education’s effect on the status of a child regrading child support at paras. 19, 20, 51. A child pursuing post-secondary education after attaining the age of majority may still be a child of the marriage if there is a valid reason for the child’s continued dependence. Determining the validity of the reason, the court must analyse whether the educational pursuits are reasonable, in the circumstances. If so, then the court must determine whether it is appropriate that the parents be required to finance the education. The child claiming the expenses must provide information of active participation in the program, such as registration, courses and grades obtained.

The Court of Appeal found that a child over the age of majority who is attending full time studies and living at home was sufficient to be a child of the marriage: De Beck v. De Beck, 2012 BCCA 465.

As the Court of Appeal stated in Shaw v. Arndt, 2016 BCCA 78 at paras. 28, 29, 31, estrangement is not necessarily determinative of whether a parent still has an obligation to support a child.