What is the test to justify a variation order?

Ontario, Canada


The following excerpt is from Eagle v. Eagle, 2004 CanLII 2561 (ON SC):

To justify a variation order, a change “must be material, and cannot be trivial or insignificant”: Hickey v. Hickey, 1999 CanLII 691 (SCC), [1999] 2 S.C.R. 518, at para. 20.

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