What is the test for material change in circumstances for a child's emotional and psychological well being?
Ontario, Canada
The following excerpt is from C.U. v. D.D., 2007 ONCJ 478 (CanLII):
[34] I acknowledge that, in that case, the situation lasted longer and was more serious than in the case before me. However, I do not think that the level of stress and degree of damage to a child’s emotional and psychological well being has to rise to the levels that they did in Montgomery v. Montgomery to justify a finding that they constitute a material change in circumstances.
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