'Personal care' within s 5(1)(b) of the Property (Relationships) Act 1984 (NSW) requires care directed to physical needs such as assistance with mobility, personal hygiene and physical comfort; emotional support alone is insufficient to establish a 'close personal relationship'. A de facto relationship ceases when one party determines not to live together with the other, even if the parties continue to share accommodation. Where a termination agreement does not comply with s 47(1) requirements, the court retains discretion under s 47(2) to disregard its terms if they are disproportionate to the parties' respective contributions.
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