[31] While respectfully disagreeing with the proposition that the enactment of The Family Law Reform Act, 1978, in itself, constitutes a material change in the circumstances of the parties, what the decision in Worthy v. Worthy does highlight is that, if all existing orders made under The Deserted Wives’ and Children’s Maintenance Act were reheard, in many cases substantially different results would be obtained. So that, where a relatively minor but material change in circumstances of either party is established (presumably even a worsening of the dependant’s financial situation), a major variation may result.
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