When is a variation proceeding not a corollary relief proceeding?

Proudfoot, J., considered whether he was dealing with a variation proceeding or a corollary relief proceeding. He held that this was not a variation proceeding because there was no "positive" order in existence. It was his view that an order must exist requiring some monetary amount specifically stated, that there must be something to vary, before dealing with the matter as a variation proceeding. Accordingly, Proudfoot, J., held that it should be a corollary relief proceeding for which only the court which granted the divorce would have jurisdiction. In coming to this conclusion he considered and followed the reasoning in Cotter v. Cotter, supra.