What is the starting point in a variation application?

Prior to May 1997, the starting point in a variation application was a consideration of whether there had been a change in circumstances since the making of the earlier court order. If there had been, and that change in circumstances was material, then the court proceeded to consider what order should be made as a result of the changed circumstances. This was set out by Sopinka J. in Willick v. Willick, 1994 CanLII 28 (SCC), [1994] 3 S.C.R. 670, 6 R.F.L. (4th) 161 (S.C.C.)at 179‑180: …The approach which a court should take is to determine first, whether the conditions for variation exist, and if they do exist, what variation of the existing order ought to be made in light of the change in circumstances. In deciding whether the conditions for variation exist, it is common ground that the change must be a material change of circumstances. This means a change, such that, if known at the time, would likely have resulted in different terms. The corollary to this is that if the matter which is relied on as constituting a change was known at, the relevant time, it cannot be relied on as the basis for variation.