Beard v. Beard

We granted applications for discretionary appeal in order to determine whether the trial court was correct in its ruling that the express provisions of a settlement agreement between the parties constitute a waiver by the husband of a right to seek a downward modification of his child support obligation, under the test set out in Varn v. Varn, 242 Ga. 309, 311 (248 SE2d 667) (1978).

The agreement provides that the parties “expressly waive any and all rights that they may have under Georgia Code Annotated Section 30-220 (a) to seek a revision of the Judicial Decree with respect to permanent…