What background evidence is required in a variation proceeding?

The variation aspect of the proceeding inevitably calls for enough historical evidence to provide the context for what is said to be the material change in circumstances. In many cases, that will be obvious, or conceded, limiting the need for more extensive background evidence. Sometimes the variation proceeding will have been the subject of a prior adjudication and in that event much of the “historical baseline” evidence along with the conceptual basis for the original spousal support award (contractual, compensatory or non-compensatory - see Bracklow, supra, Paragraphs 40 to 43 and Gabb v. Gabb, 2001 MBCA 19) may be found in the Reasons for Decision. An agreed statement of facts may obviate the need for some of that evidence but in a case such as this, that would be little more than a judicial pipedream.