An indirect financial contribution to the conservation of a partner's property through unremunerated work in the partner's business may be assessed as 'very small' where there is no direct evidence that business revenue was used to pay the mortgage, the mortgage was serviced before and after the claimant's involvement, and the business did not require a replacement worker. A holistic value judgment approach to determining a just and equitable adjustment under s 20 of the Property (Relationships) Act 1984 (NSW) is legitimate even where the resulting figure cannot be precisely explained by reference to specific contributions.
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