What is the test for determining whether a spouse has a reasonable educational need?
Ontario, Canada
The following excerpt is from Baberakubona v. Kanso, 2014 ONSC 697 (CanLII):
The second stage of the test will be fact based. In Zagar v. Zagar, 2006 ONCA 296, Karswick J. found that the husband’s unemployment was not by virtue of his reasonable educational needs. In coming to this conclusion, the court was guided by the fact that the spouse’s children would suffer financially. Further, he had not taken steps prior to enrolling in the educational program to provide for his children.
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