What is the test for a variation of a custody and access order?
British Columbia, Canada
The following excerpt is from B.D. v. L.K., 2004 BCSC 801 (CanLII):
Applying the test in Gordon v. Goertz, 1996 CanLII 191 (SCC), [1996] 2 S.C.R. 27 for the variation of an order in family matters, I considered whether the applicant had established a material change in circumstances. I found that he had not. Accordingly, I declined to vary the orders for custody and access.
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