What is the test for hardship when determining whether or not to order the return of unpaid child support?

Michel v. Graydon stated the following in relation to hardship: a. While the focus is on hardship to the payor, that hardship can only be assessed after taking into account the hardship which would be caused to the child and the recipient parent from not ordering the payment of sums owing but unpaid. b. If there is the potential for hardship to the payor, but there is also blameworthy conduct which precipitated or exacerbated the delay, it may be open to the courts to disregard the presence of hardship. c. The court must remember that the payor had the benefit of the unpaid child support for the full period of time that it was unpaid. Those monies may have funded a preferred lifestyle or the acquisition of property. In contrast, if inappropriate support was being paid, the recipient parent may have been deprived of lifestyle or property opportunities, because they were forced to spend their money (and perhaps incur indebtedness) for the benefit of the child. d. In all cases, hardship may be addressed by the form of payment.