“When considering the duration of spousal support claims once entitlement is established, the court should consider the objective of self-sufficiency set out in s. 15.2(4) of the Divorce Act.
In Fisher v. Fisher, 2008 ONCA 11 (CanLII), 2008 232 O.A.C. 213, at para. 53, the Court of Appeal observed:
Self-sufficiency, with its connotation of economic independence, is a relative concept. It is not achieved simply because a former spouse can meet basic expenses on a particular amount of income; rather, self-sufficiency relates to the ability to support a reasonable standard of living. It is to be assessed in relation to the economic partnership the parties enjoyed and could sustain during cohabitation, and that they can reasonably anticipate after separation…. Thus, a determination of self-sufficiency requires consideration of the parties’ present and potential incomes, their standard of living during marriage, the efficacy of any suggested steps to increase a party’s means, the parties’ likely post-separation circumstances (including the impact of equalization of their property), the duration of their cohabitation and any other relevant factors.
The Court of Appeal in Reisman v. Reisman, 2014 ONCA 109 at para 28 discussed the objective of self-sufficiency:
… However, promoting self-sufficiency cannot be the only consideration that determines the duration of a support order. The court also has to take into account the recipient spouse’s age, skills, education, opportunities for retraining and, importantly, her realistic prospects of being able to find a job that enables her to become self-sufficient.”