The discretion under s 20 of the Property (Relationships) Act 1984 (NSW) involves an evaluation, and an appellate court will not interfere where no error of principle is demonstrated, particularly for adjustments of minor proportions. A trial judge is entitled to apply a ratio replicating the parties' respective contributions at the commencement of the relationship where factual findings support that the acquisition of property during the relationship was attributable to the relationship itself. Mathematical errors in orders may be corrected under the slip rule rather than requiring appellate intervention.
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