(1) Enforcing a domestic contract with religious aspects
 Ontario courts have dealt with obligations under a maher
on a number of occasions: Ghaznavi v. Kashif-Ul-Haque, 
O.J. No. 3023, 2011 ONSC 4062 (S.C.J.); Yar v. Yar,  O.J.
No. 547, 2015 ONSC 151 (S.C.J.); Bari v. Nassr,  O.J.
No. 3834, 2015 ONSC 4318 (S.C.J.); Boustanji v. Barazi, 
O.J. No. 3669, 2017 ONSC 4261 (S.C.J.); Mohammadi v. Safari,
 O.J. No. 4201, 2017 ONSC 4696 (S.C.J.); and Khanis, supra.
 Courts have proceeded on the basis that agreements that
satisfy the elements of a valid civil contract may be legally
enforceable even where they have a religious aspect since the
Supreme Court’s decision in Marcovitz v. Bruker,  3 S.C.R.
607,  S.C.J. No. 54, 2007 SCC 54. At para. 123 of
Marcovitz, the Supreme Court held that “if a spouse can show
that the religious marriage contract meets all the requirements
for a civil contract under provincial legislation, then the
courts may order the fulfilment of undertakings to pay the
amounts provided for in the contract”. Ontario courts have
followed Marcovitz and enforced mahers that satisfy the FLA’s
domestic contract requirements in cases such as Khanis, Bari
 These cases treat mahers like any other contract that
may impose a variety of different legal obligations. The outcome
of each case depends, just as in any other case of contractual
interpretation, on the objective intentions of the parties as
ascertained through the particular wording of the maher when
read as a whole and considered in light of its factual matrix. As
such, evidence about the religious and/or cultural significance of
the maher to the parties could conceivably be relevant to the factual matrix in determining their objective contractual intentions. In the final analysis, however, the court’s role is confined
to enforcing only those undertakings that fulfil the requirements
of a civil domestic contract under provincial legislation.
(2) The standard of review
 The trial judge’s conclusion as to the effect of the maher
on the husband’s obligations to the wife was twofold. First,
he determined that the maher payment was enforceable as
a demand obligation. Second, he determined that the maher
payment was not included in the NFP.
 The Supreme Court set out the guiding principles concerning the standard of review on appeals from judicial decisions in
Housen v. Nikolaisen,  2 S.C.R. 235,  S.C.J. No. 31,