How have the courts interpreted the meaning of section 65(1)(e) of the Rules of Civil Procedure in the context of an individual's ability to be self-sufficient?

British Columbia, Canada


The following excerpt is from Hart v. Hart, 2012 BCSC 334 (CanLII):

In Bain v. Bain, 2008 BCCA 49, Madam Justice Huddart, in considering s. 65(1)(e), concluded at para. 37: The analysis in this case must begin with their means or their potential means to remain self-sufficient while fulfilling their obligations to their children.

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