What is the test for a corollary relief under the Divorce Act?

In my view, Cheng v. Liu does not support the respondent’s position or the appeal judge’s analysis. The issue in Cheng v. Liu was whether an Ontario court had jurisdiction to adjudicate a claim for corollary relief under the federal Divorce Act despite the fact that the parties’ divorce had been validly granted by a foreign court, without providing for corollary relief. The division of powers between the federal and provincial governments was at issue in that case. That is, while the federal government has jurisdiction over marriage and divorce, the province governs matters of property. In this way, the power to award support under the federal Divorce Act is limited to cases where the support is a corollary to the divorce. This court concluded that since the foreign divorce was silent on support, support could be awarded under the Ontario Family Law Act.