Is spousal support awarded on an indefinite basis?

For these reasons, I consider an award of spousal support should be made in favour of the plaintiff on an indefinite basis. In his submissions, the defendant asked the court “to make a final decision in the matter of the quantum and duration of the plaintiff’s entitlement to support without provision for a further review under s. 15.2”. This position is supported by the court’s decision in Leskun v. Leskun, 2006 SCC 25 at para. 39, [2006] 1 S.C.R. 920: Insofar as possible, courts should resolve the controversies before them and make an order which is permanent subject only to change under s. 17 on proof of a change of circumstances. If the s. 15.2 court considers it essential (as here) to identify an issue for future review, the issue should be tightly delimited in the s. 15.2 order. This is because on a "review" nobody bears an onus to show changed circumstances. Failure to tightly circumscribe the issue will inevitably be seen by one or other of the parties as an invitation simply to reargue their case. That is what happened here. The more precise condition stated in the reasons of the trial judge was excessively broadened in the formal order. This resulted in a measure of avoidable confusion in the subsequent proceedings.