What is the current state of the law in relation to the issue of “reasonably necessary” access?

Unlike the situation in Fallowfield v. Bourgault, supra. the Applicants do not seek to enter any of the servient tenement lands outside the easement, nor do they seek to do anything which is inconsistent with or additional to the purpose of the grant, namely to secure beach access. Nothing has changed since the granting of the easement that requires the exercise of an implied ancillary right. The Duncans are not seeking to use the easement for any new or changed purpose. They are not attempting to expand or extend the easement rights since there was never a restriction on their rights of access. As a result, in my view, the issue of what is “reasonably necessary” does not arise. The Duncans are not seeking judicial approval of an ancillary right, but rather a confirmation of the existing express terms of the easement.