What is the test for a review of an interim order for spousal support?

Saskatchewan, Canada

The following excerpt is from Bjarnason v Bjarnason, 2012 SKQB 445 (CanLII):

The petitioner shall exert reasonable efforts to obtain employment and report the particulars of any employment which she procures to the respondent within seven days of obtaining such employment. Given the uncertainty of the petitioner’s employment prospects, a review of this interim spousal support order can occur at the behest of either party when the petitioner has obtained employment or one year hence, whichever is the earlier. Such review is to be under s. 15 of the Divorce Act and not a variation proceeding. See Leskun v. Leskun 2006 SCC 25, [2006] 1 S.C.R. 920. Leskun permits a s. 15.2 review where a genuine and material uncertainty exists at the time of the interim order, permitting either spouse to bring a further motion to determine whether this order should be altered without the necessity of demonstrating a material change of circumstance.

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