A claim for equitable compensation or constructive trust arising from a de facto relationship requires proof of a joint endeavour or enterprise of a commercial nature, with an actual intention (express or inferred) to pool resources for mutual material benefit. The mere performance of homemaker duties in a de facto relationship, without more, does not establish the requisite joint endeavour. The South Australian decision in Parij v Parij, to the extent it suggests otherwise, should not be followed in Western Australia.
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