Does the wife have satisfied the considerable onus upon her in her maintenance agreement with the other spouse?

All in all, I cannot find that she has satisfied the considerable onus upon her; and I adopt with respect the observations of Anderson J. in Dal Santo v. Dal Santo (1975), 21 R.F.L. 117 (B.C.), where he, summing up what I take to be the law on this subject, said [p. 120]: “The wife did not ask for maintenance at the time the separation agreement was signed, and I see no reason why she should not be held to her bargain. “It is of great importance not only to the parties but to the community as a whole that contracts of this kind should not be lightly distburbed. Lawyers must be able to advise their clients in respect of their future rights and obligations with some degree of certainty. Clients must be able to rely on these agreements and know with some degree of assurance that once a separation agreement is executed their affairs have been settled on a permanent basis. The courts must encourage parties to settle their differences without recourse to litigation. The modern approach in family law is to mediate and conciliate so as to enable the parties to make a fresh start in life on a secure basis. If separation agreements can be varied at will, it will become much more difficult to persuade the parties to enter into such agreements.”