A 21-year estrangement between an applicant and the deceased does not disentitle the applicant from a family provision order where the estrangement was partly attributable to the conduct of the deceased and other beneficiaries. The court must consider the character and conduct of all parties, not just the applicant, in evaluating the relationship. Where a provision order disproportionately reduces the share of a non-party beneficiary with similar needs, the court may vary the order to equalise shares.
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