What is the test for a variation of a corollary relief granted pursuant to the Divorce Act?
Saskatchewan, Canada
The following excerpt is from Murray v. Murray, 1997 CanLII 11226 (SK QB):
The application seeks to vary the corollary relief granted pursuant to the Divorce Act. In order to obtain a variation of such corollary relief an applicant must demonstrate a material change in circumstances; Willick v. Willick (1994), 1994 CanLII 28 (SCC), 6 R.F.L. (4th) 161 (S.C.C.). If one looks to the circumstances as they existed as of the date of hearing, there was no material change of circumstance.
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