Can a parent in loco parentis withdraw from the obligation of paying child support?

In Andrews v. Andrews, 1992 CanLII 8326 (SK CA), 38 R.F.L. (3d) 200 (Sask. C.A.), Vancise, J.A., rejects the rationale of Huband, J.A., as set forth in Carignan, and concludes that a parent in loco parentis cannot unilaterally withdraw from the obligation to support a child or children. On pp. 214 and 215, he sets out the process he feels should be followed in determining whether maintenance should be paid where the question of in loco parentis is in issue. That process is as follows: (1) Determine whether the person has, during the course of the marriage, by voluntarily assuming the parental obligation of pecuniary support and parental needs, stood in loco parentis in respect of his or her spouse’s children; (2) A person who stands in loco parentis to a child or children of the other spouse has a prima facie obligation to support the child or children; (3) If the parent stands in loco parentis to the child, such parent cannot unilaterally or at his or her option withdraw from the status or from the obligation to support the child by withdrawing from the child’s life or by refusing to continue pecuniary support. (4) Examine the relationship between the parent in loco parentis and the children since the separation or divorce, where no prior order for support has been made, to determine whether it is just and reasonable to make such an order considering such elements as the parental role which existed, the parental role after the separation, the contact between such parent and the child or children, and, where appropriate, the wishes of the children (see Rathwell); and (5) If an order for support has been made, it is necessary to examine whether or not there have been any changes in circumstances between the person in loco parentis and the child or children which would justify making a variation order. Such circumstances, which are not intended to be exhaustive, would include a change in relationship between the parent in loco parentis indicating that the children no longer consider him to be a father figure, where the parent plays no role in the parenting and guidance of the child, and where there has been no contact between the parties.