What constitutes a material change of circumstance on a variation application?

Saskatchewan, Canada


The following excerpt is from H.S. v. C. S., 2004 SKQB 492 (CanLII):

It is well propounded law that a relocation which would significantly affect the relationship of the children with the access parent constitutes a material change of circumstance—the threshold step of any variation application: Gordon v. Goertz, 1996 CanLII 191 (SCC), [1996] 2 S.C.R. 27.

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