Does the existence of a payor’s income arrears operate to support a request for a reduction in support?

I can conceive of a scenario where the existence of arrears might operate to support a payor’s request for a reduction. Such unusual circumstances were found in Trembley v. Daley.[2] In that case, the payor had suffered a “catastrophic injury” to his hand some years after the making of the final support order, as a result of which he could no longer perform the manual work which had been the sole source of his income. Overwhelming hardship to the payor caused by that injury emerged as the prevailing consideration in that case. In those circumstances, it would be understandable that the court would take into account the ability of a payor to satisfy existing support arrears given the payor’s permanently diminished earning capacity stemming from the catastrophic injury.