What is the test for changing a temporary placement order during the adjournment of a protection application?

Ontario, Canada


The following excerpt is from DBCFS v. C.T. et al., 2022 ONSC 1185 (CanLII):

As stated by Himel J. in Children’s Aid Society of Toronto v. L.L. (2003), when changing a temporary placement order during the adjournment of a protection application the court must find a material change in circumstances since the making of the last court order.[7]

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