Ontario, Canada
The following excerpt is from Duffus v. Walters, 2017 ONCJ 215 (CanLII):
In order to determine if the conditions for a variation exist, the change of circumstances must be material as opposed to trivial or insignificant. Hickey v. Hickey, 1999 CanLII 691 (S.C.C.), [1999] 2 S.C.R. 518.
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