Retroactive spousal support considered on the same basis as child support

S.P. v. R.P., 2011 ONCA 336 is an important decision dealing with, among other things, retroactive support for children and spouses. The Court held that retroactive spousal support is to be considered under the same principles as retroactive child support:

[59]         The principles relating to the award of retroactive spousal support are similar to those considered in the award of retroactive child support. In Kerr v. Baranow, 2011 SCC 10, Cromwell J. for the court stated at para. 207:

…similar considerations to those set out in the context of child support are also relevant in deciding the suitability of a "retroactive" award of spousal support. Specifically, these factors are the needs of the recipient, the conduct of the payor, the reason for the delay in seeking support and any hardship the retroactive award may occasion on the payor spouse. However, in spousal support cases, these factors must be considered and weighed in light of the different legal principles and objectives that underpin spousal as compared with child support.