Does a review date set after a fixed date need to be reviewed?

Manitoba, Canada


The following excerpt is from F.M.R-B. v. T.D.B., 2006 MBQB 16 (CanLII):

Although the facts are quite different, I am attracted to the approach of Monnin, C.J.Q.B. in Hrabarchuk v. Todosey, 2005 MBQB 301, [2005] M.J. No. 504 wherein he set a review date permitting the payor to have his ongoing obligation (in particular, the indefinite nature of same) reviewed after a fixed date without the necessity of establishing the change of circumstances required to support a variation of an existing order (see para. 60 of Hrabarchuk, supra).

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