What considerations have been considered in the context of a change of venue in a family law case?

Ontario, Canada

The following excerpt is from Comstock v. Comstock, 2005 CanLII 9669 (ON SC):

In addition to the above considerations, the question of fairness, or more specifically, the lack of fairness that might result from a decision about a change of venue, appears to be a consideration found in the jurisprudence. In Ridley v. Ridley, [1989] O.J. No. 1121 (O.H.C.), a choice of venue that resulted in a party’s inability to be present at the trial for financial reasons was found to touch on the fairness of the trial and should be avoided. This would also be consistent with the directive found in Rule 2(3) of the Family Law Rules.

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