In property adjustment proceedings under the Property (Relationships) Act 1984, both gross and net values of properties at the commencement of a de facto relationship may be relevant: gross values may indicate proportions affected by market increases, while net values reflect actual equity. Where evidence is inadequate to determine the breakdown of property value increases (market forces versus improvements versus mortgage payments), a trial court doing its best on inadequate material will not be overturned on appeal if the result is within the range of reasonable outcomes.
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