January 8, 2026 – Varying Temporary Support Orders

“In Edisbury v. Edisbury, 2022 ONSC 2407, starting at para. 33, Finlayson J. described the test to vary an interim support order:

(a) whether there is a strong prima facie case that there has been a material change in circumstances since the time of the order in question;

(b) whether there is a clear case of hardship.

(c) whether there is a situation of urgency; and

(d) whether the moving party comes to court with “clean hands”.”

Vigneault v. St. Jacques, 2025 ONSC 127 (CanLII) at 14

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