In this case the parties settled their financial issues by a nominal support order, which is generally understood to have been a device formerly used by parties to a marriage breakdown to preserve the receiving spouse's right to apply for effective spousal maintenance through a variation. In that sense, the 1981 consent order was not intended to be a final settlement of the spousal support issue order, and Pelech v. Pelech, 1987 CanLII 57 (SCC),  1 S.C.R. 801 does not apply: Moge v. Moge p.839.
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