Can a parent avoid child support obligations by reducing their income by obtaining an education?

[106] As set out in Drygala v. Pauli, a parent cannot avoid his/her child support obligations by a self-induced reduction of income. Where obtaining an education is the reason for self-reduced income, once it is proved that a spouse is intentionally under, or unemployed, the onus then shifts to that spouse to establish what is required by virtue of his/her reasonable educational needs.