What is the test for retroactive spousal support?

The trial judge then turned to retroactive spousal support. She referred to the direction in Kerr v. Baranow, 2011 SCC 10, at para. 207 that “the considerations with regard to the suitability of retroactive spousal support are similar to those applicable to retroactive awards of child support.” She then said at para. 34: I will not repeat what I said earlier about delay, hardship, or the conduct of the payor. I will say that I am satisfied that the recipient has, that is to say, the claimant has, and has had a real need for spousal support and that she will have to be put in a position to pursue job-training and/or further education if she is to have a realistic possibility of attaining self-sufficiency. As with child support, the trial judge increased spousal support retroactive to December 1, 2011. She concluded that spousal support should end as of March 31, 2015, the month in which the summary trial was heard.