Does a master’s decision regarding interim custody and access need to be reviewed?

In Kalafchi, Harris J.A. reiterates there is no absolute rule that a master’s decision regarding interim custody and access will invariably be regarded as purely interlocutory and only reviewable if the decision is clearly wrong: Kalafchi at para. 15 citing Thibeault v. Ravelo, [1999] B.C.J. No. 1457 (S.C.). Harris J.A. states, at para. 16, that determining whether an order is interlocutory requires a case-by-case analysis based on the “factual consequences of the order in the context of the case as pleaded” and he later affirms that a rehearing may be warranted in certain circumstances: