In my respectful view, the correct threshold for this variation application is that set out in s. 17(4.1) of the Act which requires the party seeking variation to establish that “... a change in the condition, means, needs or other circumstances of either former spouse has occurred since the making of the spousal support order...”. A change will be sufficient within the meaning of this section if it is one that, if the court had known about it at the time of the original order, the order made would likely have had different terms: Willick v. Willick, 1994 CanLII 28 (SCC), [1994] 3 S.C.R. 670 at 688.
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