In Andrews v. Andrews, supra, a husband sought the inclusion of a review order in an indefinite support award. In refusing that relief, Laskin J.A., writing for the court, noted that a failure to make reasonable efforts to contribute to one's own support may amount to a material change in circumstances. In respect of review orders more generally, he indicated: "I do not think that the court should routinely make review orders" (para. 37). [See Note 15 below] He added that this was particularly so on appeal, when the trial judge had not seen fit to do so.
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