What is the test for retroactive variation of a child support order?

Ontario, Canada


The following excerpt is from Knight v. Rowntree, 2018 ONCJ 999 (CanLII):

To date, where a retroactive variation is sought when the child is no longer entitled to support, as I have determined to be the case in this instance, the courts have seen fit to entertain the request in motion to change proceedings where there is an existing order and an established support obligation under the Family Law Act.[Smith v. McQuinn, supra].

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