Can a court vary a final order pursuant to the Children's Law Reform Act?

In Crawford v. Dixon, in 2001, Granger J. dealt with the issue of an interim variation of a final custody order pursuant to the Children’s Law Reform Act.[1] He reviewed the jurisprudence against and in favour of a discretion to make an interim variation of a final order for custody or access and concluded that the court has such a discretion, to be exercised in clear cases: On balance, although the court should not make it a practice to vary final orders on an interim basis, if the moving party makes out a clear case for relief and proves that the need for the variation is urgent, there seems to be little reason to deny the power to vary. Such a denial might encourage the other side to delay.[2] The Impact of the Change on the Children