In a large estate, proper provision for an adult child under the Family Provision Act 1982 (NSW) is not limited to a modest capital fund for contingencies merely because the applicant has existing accommodation and income through family arrangements. Provision may extend to accommodation, a secure income independent of family trust distributions, and a capital fund for contingencies, assessed by reference to all circumstances including the size of the estate, the totality of the relationship, and the position of other beneficiaries. The question is not whether provision is necessary to meet financial needs in the sense of necessities, but whether it is proper having regard to all relevant circumstances.
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