Zreika and Lozano (Child support)

The matter of *Zreika and Lozano* concerned a dispute over child support payments, brought before the court for review. The central issue was whether payments made by one parent to a third party constituted a valid discharge of their child support obligations, effectively acting in lieu of direct child support payments.

The court was required to determine the intention of both parents regarding these third-party payments. Specifically, it needed to ascertain whether both parents mutually agreed that these payments would satisfy the child support assessment, thereby releasing the paying parent from their obligation to pay child support directly to the other parent or through the Child Support Agency.

The court affirmed the decision under review, finding that the payments made to the third party were not intended by both parents to be in lieu of child support. The legal principle applied focused on the necessity of a clear and unequivocal agreement between both parents that such third-party payments would discharge the child support liability. In the absence of such mutual intention, the payments were not considered to have satisfied the child support obligations.