“Interim support motions are not meant to take the place of a trial. Instead, they are meant to allow the parties to maintain a reasonable lifestyle until the full merits of a case can be determined at trial: Charbonneau v. Charbonneau 2004 CanLII 47773 (ON SC), [2004] O.J. No. 5059 (SCJ). Even when, as here, there is no issue of entitlement, courts generally do not engage in a detailed examination of the merits of a case at the interim motion stage: ibid. While a court is not precluded from making temporary retroactive support orders where merited, particularly in the face of blameworthy conduct, it should be cautious in making such an order since there has been no questioning. The trial judge is in the best position to conduct the necessary holistic analysis of the D.B.S. factors: Palaganas v. Marshall, 2016 ONCJ 445, at para. 57-60 (see below for citation of the D.B.S. case).
That being said, it is open to a motions court to make an interim retrospective or even a retroactive support order when there is clear entitlement and blameworthy conduct that benefits the payor to the disadvantage of the recipient: Palaganas v. Marshall, at para 60-61, citing Samis (Guardian of) v. Samis, 2011 ONCJ 273 (CanLII), [2011] O.J. No. 2381 (OCJ), at para. 91.”