Section 20 of the Property (Relationships) Act 1984 (NSW) does not require a different or lesser approach to evaluating contributions made during a close personal relationship as compared with a de facto relationship; the approach depends on the facts and specific contributions in each case. Reference to outcomes in other cases as providing a tariff or range for s 20 adjustments is misleading and unhelpful, as it tends to ossify the evaluative judgment and distract from the statutory task. The smaller the asset pool, the more significant the homemaker contribution and the less significant the financial contributions.
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1 of the 6 citing cases carry a classified treatment. How each court treated it is available to signed-in members.