October 15, 2025 – Is the Passage of Time a Material Change in Circumstances?

“W.G. has urged me to find that the passage of time amounts to a change of circumstances. Several appeal-level decisions have held that the mere passage of time cannot amount to a change in circumstances. (For a recent example and a good discussion on this issue, see: Townsend v. Townsend, 2023 SKCA 91.) However, this issue is nuanced and not without controversy.”

          W.G. v. K.G., 2024 ONSC 5716 (CanLII) at 31

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