What would have been required if an order was made before the application was made?
British Columbia, Canada
The following excerpt is from N.K.P. v. D.W.S., 2006 BCPC 6 (CanLII):
Had there been an order made before the application, or indeed before the move to the Island, the applicant mother would have had to show a change in circumstances since that order, to satisfy the threshold test established under Gordon v. Goertz, 1996 CanLII 191 (SCC), [1996] 2 S.C.R. 27.
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