Can a variation be relied on as a basis for variation?
Ontario, Canada
The following excerpt is from Maceus-Agyekum v. Agyekum, 2005 CanLII 10539 (ON SC):
In Willick v. Willick (1994), 1994 CanLII 28 (SCC), 6 R.F.L. (4th) 161 SCC, Sopinka J. stated: … if the matter relied on as constituting a change was known at the relevant time it cannot be relied on as the basis for variation.
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