“The necessity that there be a finding of a material change in circumstances as a prerequisite to an examination of the merits of an application to vary an existing custody or access order was recently confirmed by Pazaratz J. in F.K. v. A.K., 2020 ONSC 3726, and by Ryan Bell J. in Joachim v. Joachim, 2021 ONSC 8584 at para. 34.
Where a party seeks a change in support provisions, the test for material change is less than one for changes in custody or parenting, but it is still a significant one: Pustai v. Pustai, 2018 ONCA 785; L.M.P. v. L.S., 2011 SCC 64.
…
Both parties make accusations against the other respecting their ability to communicate in Brody’s best interests. Unfortunately, this is not a novel issue. Their antagonism pre-existed the agreed Minutes of Settlement which were crystallized in the Order of Gordon J.
Each has presented a blizzard of affidavits trading insults and constituting a catalog of petty grievances against the other, recounting a dispiriting parade of minor incidents, such as the acrimony about a wart on Brody’s toe, or an earache, or a birthday cake.
These do not amount to a material change in circumstances. None justify an alteration in the arrangements previously agreed to by the parties and prescribed on consent in the Order of July 11, 2019. I do not accept the contention of the applicant that there has been a material change in circumstances due to the respondent’s inability to meet Brody’s needs in a timely and effective manner as a result of her animosity towards the applicant, and that this was not foreseen at the time that the parties signed Final Minutes of Settlement and obtained the Order on consent. Both parties have engaged in a “tit-for-tat” series of recriminations. An absence of maturity on the part of both parties, or a desire of one to control the other, does not warrant a finding of a material change in circumstances or a variation in the Order.”
Stevenson v. Hargreaves, 2022 ONSC 5971 (CanLII) at 11-12, 14-16