What constitutes a material change in circumstances for a temporary placement order?

In Catholic Children’s Aid Society of Toronto v. M. (R.), 2017 ONCJ 784, the court stated that courts should take a flexible approach in interpreting what constitutes a material change in circumstances, and take a flexible approach about what factors will be considered when determining whether it should change the temporary placement order once the material change has been established. The change in circumstances required to change a temporary placement order should only need to be “sufficiently material”. What change is sufficiently material will depend on the circumstances of the case. Once a material change in circumstances is established, a contextual analysis should be conducted by the court to determine if the placement order should be changed. The purposes of section 1 of the act should always be at the forefront of the analysis.