What is the test for a temporary order requiring material change in the care of a child?

The judge’s reference to a material change might cause concern. However, the judge did consider other situations as an aid to the approach and interpretation of the applicable statutory provision here. He does reference “protection language” and adopts the test of Curtis, J. in Children’s Aid Society of Toronto v. L.G., 2012 ONCJ, that to be successful in a temporary hearing, the best interests of the child must require a change in the care of the child. He properly regarded this as “strong language” and appreciated the test as the best interests of the child.