What is the threshold for a material change in circumstances?

British Columbia, Canada


The following excerpt is from Kearns v. Kearns, 2013 BCSC 77 (CanLII):

The parties take the position that the threshold question enunciated in Gordon v. Goertz does not apply because there is no final order dealing with custody, guardianship and access. I agree there is no requirement that a material change in circumstances be established since this is the initial determination of the issues of custody, guardianship and access.

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