When assessing property adjustment under s 20 of the De Facto Relationships Act 1984, the court must take into account benefits received by the applicant during the relationship, including rental income generated from properties freed up by the respondent's provision of accommodation. The fact that it was a joint decision to cohabit does not preclude consideration of such benefits. The question whether pre-cohabitation contributions made in mutual anticipation of the relationship may be considered under s 20 remains unresolved.
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