What are the exceptions for making personal expenses payments in lieu of support?

One of the narrow exceptions is where there is express agreement or acquiescence by the payee that the payments should be made in lieu of support. Another exception is where payments are made on behalf of children for expenses that are reasonable and that the payee would necessarily have incurred in any case: Bale v. Bale, [2001] O.J. No. 4196 (Sup. Ct.). I note that in Bale, Aston J. expressly stated that the exceptions should be applied narrowly, as credit for voluntary payments sets a “dangerous precedent” (at para. 21).