What is the test for a material change in a child protection order?

Nova Scotia, Canada


The following excerpt is from Bushell v. Griffiths, 2013 NSSC 68 (CanLII):

A material change is one which has not been foreseen or could not have been reasonably contemplated by the judge who made the original order: Gordon v. Goertz, supra. A material change must be more than a temporary or minor change. The change must be a substantial continuing one which impacts the child and the ability of the parents to meet the needs of the child.

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