The applicant moved to change a long-standing spousal support order after paying support for nearly 19 years following an 18-year marriage.
He relied on new family responsibilities, health concerns, reduced working hours, and the Spousal Support Advisory Guidelines to argue that support should terminate.
The court held that the record did not permit a finding of a material change in circumstances within the meaning of s. 17 of the Divorce Act, and that speculative future income loss could not ground variation.
In any event, the court found the respondent remained both entitled to and in need of support on compensatory and non-compensatory bases, and dismissed the application.