What is the test for obtaining a review order to force a plaintiff to become self-sufficient?

Manitoba, Canada


The following excerpt is from Caldarola v. Buscemi, 2012 MBQB 203 (CanLII):

I note the comments in Leskun v. Leskun, 2006 SCC 25, [2006] 1 S.C.R. 920, firstly, regarding the fact there is not an overriding “duty’ to become self-sufficient, but that this is simply one of the factors for the court to consider (para. 27) and secondly, that review orders are not desirable as a general rule.

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