Does the delivery of a s. 112 assessment report constitute a material change in circumstances justifying a change in the existing arrangement?

Ontario, Canada


The following excerpt is from Ly v Wade, Houle, 2016 ONSC 1155 (CanLII):

32. The delivery of a s. 112 report does not in itself constitute a material change in circumstances justifying a change in an existing arrangement. Marcy v. Belmore (supra). And parties should not perceive the arrival of an assessment report as creating an automatic strategic opportunity to secure a more favourable status quo, heading into trial.

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