What is the test for a review of spousal support?

The appellant relies heavily on Celotti v. Celotti (2007), 2007 CanLII 23909 (ON SC), 40 R.F.L. (6th) 411 (Ont. Sup. Ct. J.). There, after a 12-year marriage and three children, the parties separated but continued to reside in the same house. About two years later, the wife became pregnant with a third party’s child. She had no ongoing relationship with the child’s biological father, and received very limited child support from him. She had been a stay-at-home mother for most of the marriage and was reluctant to take steps to return to the workforce, in part due to the infancy of her fourth child. The trial judge awarded her spousal support, and addressed the issues raised by the fourth child in the context of the appropriate date for a future review of that order. The wife sought a review in nine years, to allow her to care for the child. The husband argued for three years, stating it was unfair to increase his financial obligations because the fourth child delayed the wife’s re-entry to the workforce. Olah J. found that while the mother was entitled to support for a period for transition from marriage back to the workforce, this should not be extended because of the fourth child. He ordered a review in two years, stating: