The concept of 'advancement in life' under s 9(2) of the Family Provision Act 1982 (NSW) encompasses provision for retirement and contingencies, and is not confined to identified specific needs. Where adult claimants have insufficient retirement provision, a close relationship with the deceased, and there are no competing claims on the estate, a finding that no provision is required may bespeak error. The smallness of the estate is a factor of little weight where there are no competing claims and the estate would otherwise pass to the Crown as bona vacantia.
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