BONNER & LANCASTER

This matter concerned an application for parenting arrangements for a ten-year-old child. The parties had previously consented to final orders in September 2017. The applicant sought to vary these orders.

The central legal issues before the court were whether the rule established in *Rice & Asplund* should be applied in the present circumstances, given the prior consent orders, and whether there had been a significant change in circumstances since those orders were made. The court was also required to consider whether the need to determine the child's best interests outweighed the principle of avoiding further litigation for the child.

Judge Brown dismissed the application, finding that the threshold for varying the existing parenting orders had not been met. The court determined that the circumstances did not warrant departing from the final orders made by consent in 2017, and that the applicant had not demonstrated a significant change in circumstances sufficient to justify further litigation concerning the child's best interests. The need to provide finality and avoid subjecting the child to ongoing disputes was given considerable weight.