A de facto relationship may exist even where the financial arrangements between the parties closely resemble a boarder arrangement, provided there is sufficient sharing of lives at the emotional and mutually supportive levels. However, where a party's financial contributions do not exceed the value of accommodation received in return, and non-financial contributions are not shown to differ from those of other household members, a property adjustment order may not be just and equitable. The case also confirms that a party's admissions in other proceedings (such as custody proceedings) describing the other party as a 'defacto' or 'partner' may be significant evidence of the nature of the relationship.
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