Non-financial contributions such as homemaking and child-rearing can found a constructive trust over properties acquired by the other party during a de facto relationship, provided those contributions facilitated the property acquisition enterprise rather than merely maintaining the personal relationship. The contribution must be directed to the acquisition and maintenance of the specific property, not simply to the welfare of the other party. A claim under Part IX of the Property Law Act 1958 (Vic) is not a caveatable interest, but an interest under a constructive trust is.
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