254 CHILD SUPPORT GUIDELINES IN CANADA, 2020
amount. However, in order to qualify for a section order, the expenses must be proven
to be “special” or “extraordinary ” in some way. is is because the basic table amounts of
child support are designed to cover all the “ordinar y” costs of raising a child. Food, shelter,
clothing, and other necessities are a ll ordinary, as are many educational, extracurricu lar,
and recreationa l expense s. “Special,” as distinct f rom “extraordinary,” expenses are gener-
ally added more or less as a routine matter, provided that the y are not unreasonably h igh,
but controversy can arise with respect to t he “necessity” for a child to be engaged in extra-
Section of the Guidelines is not presumptive; it indicates that a cour t may on either
spouse’s request provide for an amount to cover all or any por tion of the expenses enumer-
ated, which expenses may be estimated t aking into account the necessity of t he expenses
in relation to the child’s best interests and the reas onableness of the expenses in relation
to means of the spouses and those of the ch ild and to the family ’s spending pattern prior
to separation . e onus is on the parent seeking a contribution to plead and prove the
expense.Although expen ses may be estimated, there must be some cogent evidence of a
An order for special or extraordinar y expenses under section of the Federal Child Sup-
port Guidelines i s not premised on a prior or concurrent order for the payment of the basic
table amount of child support. A non-prima ry residential parent m ay seek contribution to
a child’s extraordinar y expenses for extracurricular act ivities and the amount ordered may
be set-off against the table amount of child support payable by the non-primary residentia l
parent. Wh ile ordering a pro rata sharing of al l of the allowable expenses under sect ion
of the Guidelines, a court may order that the mother shall a ssume the primary respon-
sibility for dealing w ith certain designated ex penditures while the father shall assume the
primar y responsibility for t he others.
Although child care ex penses, medical and dental i nsurance, health-related expenses,
and post-secondary educational expenses need not be ext raordinary under sect ions ()(a),
(b), (c), and (e) of the Federal Child Support Guidelines in order to warra nt a judicial alloca-
tion, expens es for primary or seconda ry school education or for any educat ional programs
that meet a child’s particu lar needs under section ()(d) of the Guidelines and expenses
for extracurricula r activities under section ()(f) of the Guidelines must be extraordi n-
ary in order to be allowable. All ex penses, however, must meet the tests of necessity and
C larke v Clarke, BCSC at para s –, Baird J; TMR v SMS, NBQB at para .
Slade v Slade,  NJ No (CA); VC v JDB, NSSC . Comp are Olaitan v MacDougall, PECA .
Sharf v Sharf,  OJ No (SCJ).
Russell v Russell, NSSC .
See H v J, NBQB (application by uncle and gr andmother).
Carr uthers v Carruthers, BCSC ; Cook v Cook, NBQB citing H v C , NBQB ;
Bradley v Brooks, N LTD(F) ; Vantomme v Vantomme, SKQB .
Howe v Lorett e, NBQB at para , Wooder J.
Whitley v W hitley,  BCJ No (SC); Davis v Davis,  BCJ No (SC); but see contra
Hannigan v Hannigan,  BCJ No (SC).
Van Bilsen v Van Bilsen,  OJ No (SCJ).
Fisher v Fisher,  OJ No (SCJ).
Bodine-Shah v Shah, BCCA ; KKS v JSS, BCSC ; WL v RW,  NBJ No (QB);
Hiscock v Hiscock, NLTD(F) ; Bocaneala v Bocaneala, NSSC ; Hoover v Hoover, 
NWTJ No (SC); MacKinnon v MacKinnon,  OJ No (CA); Titova v Titov, ONCA ;
Beisel v Henderson,  SJ No (QB).