© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2000] VSC 328
Supreme Court of Victoria
2000-09-15
Kellam J
Original judgment source is linked above.
PROPERTY LAW - property of de facto partners - financial contribution - contribution as homemaker or parent - relevance of "negative contribution" by way of financial irresponsibility and alcoholism of one party - Property Law Act 1958 (Vic), Pt IX, ss. 275, 285.
(a) The former matrimonial home situated at 130 Marshall Street, Ivanhoe which has an agreed value of $750,000 and which has been occupied by the defendant and the children since the separation of the parties in October 1997.
(b) Investment properties as follows:
(i) 1 Como Street, Alphington which has an agreed value of $300,000.
(ii) 816 Heidelberg Road, Alphington which has an agreed value of $275,000.
(iii) 826 Heidelberg Road, Alphington which has an agreed value of $205,000.
(iv) 828 Heidelberg Road, Alphington which has an agreed value of $200,000.
(c) A business known as Gumnut Child Care Centre ("Gumnut"), the value of which is the subject of dispute between the parties.
(d) Shares in joint names valued at $29,130.
(e) Shares in the name of the defendant the value of which is in dispute between the parties.
(f) Fees owing to Gumnut, tools, equipment, and a boat totalling approximately $18,000.
The above assets have a total value of approximately $1.8 million. The defendant contends that liabilities of the parties total approximately $750,000 and that the total net assets of the parties are approximately $1,050,000. The liabilities include loans made to Gumnut by the defendant as well as other debts of Gumnut. The plaintiff asserts that the net assets of the parties amount to a sum of approximately $1.48 million.
"(1) The Court may make an order adjusting the interests of the de facto partners in the property of one or both of them that seems just and equitable to it having regard to - (a) the financial and non-financial contributions made directly or indirectly by or on behalf of the de facto partners to the acquisition, conservation or improvement of any of the property or to the financial resources of one or both of the partners; and (b) the contributions, including any contributions made in the capacity of home-maker or parent, made by either of the de facto partners to the welfare of the other de facto partner or to the welfare of the family constituted by the partners and one or more of the following -
ii. a child accepted by one or both of the partners into their household, whether or not the child is a child of either of the partners; and
iii. any written agreement entered into by the de facto partners.
(2) A Court may make the order whether or not it has declared the title or rights of a de facto partner in respect of the property."
" This Part as in force immediately before the commencement of Part 2 of the Property Law (Amendment) Act 1998 continues to apply in relation to a person who was a partner in a de facto relationship which ended before the commencement of Part 2 of that Act whether or not proceedings had been commenced under this Part as so in force."
"285. Order for adjustment (1) A court may make an order adjusting the interests of the de facto partners in the real property of one or both of them that seems just and equitable to it having regard to - (a) the financial and non-financial contributions made directly or indirectly by or on behalf of the de facto partners to the acquisition, conservation or improvement of any of the property or to the financial resources of one or both of the partners; and (b) the contributions, including any contributions made in the capacity of homemaker or parent, made by either of the de facto partners to the welfare of the other de facto partner or to the welfare of the family constituted by the partners and one or more of the following - (i) a child of the partners; (ii) a child accepted by one or both of the partners into their household, whether or not the child is a child of either of the partners; and (c) any written agreement entered into by the de facto partners. (2) A court may make the order whether or not it has declared the title or rights of a de facto partner in respect of the real property."
(a) a prospective claim or entitlement in respect of a scheme, fund or arrangement under which superannuation, retirement or similar benefits are provided; and
(b) property which, under a discretionary trust, may become used for the purposes of or vested in one or both of the de factor partners; and
(c) property, the alienation or disposition of which is wholly or partly under the control of one or both of the de facto partners and which is lawfully capable of being used for the purposes of one or both of the de facto partners; and
(d) any other valuable benefit."
"Property" is defined in s.275 of the Act as including:
"Real and personal property and any estate or interest in real or personal property, and money, and any debt, and any cause of action for damages (including damages for personal injury), and any other thing in action, and any right with respect to property."
"It is, of course, the fact that the Victorian legislation authorizes the Court to make orders for the adjustment of interests with respect only to real property. There are no provisions concerned with the making of orders for maintenance such as those to be found in the Family Law Act, and the New South Wales de facto legislation and it is apparent that the objectives sought to be achieved by the legislation are limited. The larger areas of operation of both the Commonwealth and New South Wales Acts require that the Courts when dealing with applications made under them, direct attention to a wider range of considerations than those which possess relevance under the Victorian provisions. Whilst it is, in my opinion, important to remain mindful of these differences, nevertheless the Court is vested with a wide discretion and must attempt to arrive at a result which is just and equitable in the circumstances. Accordingly it must have regard to the whole of the relevant context within which an application is made. Any assessment of the significance and value of the assistance and support provided by de facto partners which did not place them within a framework provided by all of the circumstances of the relationship, would introduce a measure of unreality into the process and a degree of tension would arise between the adoption of a restrictive approach to the factors to be taken into account, and the duty of the Court to attempt to achieve equity between the partners. Whilst s.285 imposes an obligation upon the Court to have regard to a number of particular kinds of contributions which may have been made, the legislation has not attempted to confine narrowly the concept of 'contribution' and there is, in my opinion, no good reason for the Courts to do so."
"In my view, it is important to avoid the erection of any rigid criteria, steps or tests governing the exercise of the Court's discretion under s.285. The Court is empowered to make an order, adjusting the interest in real property, that seems just and equitable to it having regard to contributions made as defined expressly by the section, but, at the same time what seems just and equitable should not and cannot be decided in a state of mind oblivious to all circumstances other than those constituted by the defined contributions."
"In assessing value at the current date a purchaser would note this trend and accordingly would judge the business as being unprofitable; with these occupancy levels and in the notional circumstance of a leasehold business with the purchaser paying rental for the two freehold properties there would clearly be no profitability. The causative factor appears to be the child care centre recently established in Ivanhoe on the corner of Lower Heidelberg Road and Marshall Street, Ivanhoe which is brand new, purpose built and is registered for 60 children."
Because he regards the child care business as unprofitable in its present circumstance he proposed an "alternative scenario" to "achieve a sale of the business". The alternative scenario proposed by Mr Bice after discussion with the defendant on site, is the operation of the business from 816 Heidelberg Road, Alphington with its current registration of 32 children.
The Contribution of the Parties as Homemakers and Parents
"In undertaking this task it is open to the court to conclude on the material before it that the indirect contribution of one party or homemaker or parent is equal to the financial contributions made to the acquisition of the matrimonial home on the footing that that party's efforts as a homemaker and parent have enabled the other to earn an income by means of which the home was acquired and financed during the marriage. To sustain this conclusion the materials before the court will need to show an equality of contribution, that the efforts of the wife in her role were equal to the husband in his".
"However, equality will be the measure, other things being equal, only if the quality of the respective contributions of husband and wife, each judged by reference to their own sphere are equal. The quality of the contribution made by a wife as homemaker or parent may vary enormously from the inadequate to the adequate to the exceptionally good. She may be an admirable housewife in every way or she may fulfil little more than the minimum requirements. Similarly, the contribution of the bread winner may vary enormously and deserves to be evaluated in comparison with that of the other party. It follows that it cannot be said of every case that where the parties reside together that equal value must be attributed to the contribution of each. That will be appropriate only to the extent that the respective contribution of the parties are made to an equal degree."
"As a statement of general principle, I am firmly of the view that financial losses incurred by parties or either of them in the course of a marriage whether such losses result from a joint or several liability, should be shared by them (although not necessarily equally) except in the following circumstances: (a) where one of the parties has embarked upon a course of conduct designed to reduce or minimise the effective value or worth of matrimonial assets, or (b) where one of the parties has acted recklessly, negligently or wantonly with matrimonial assets, the overall effect of which has reduced or minimised their value."
1. Order that the plaintiff transfer to the defendant all of her right title and interest in all those pieces of land being situated at 1 Como Street, Alphington, 816 Heidelberg Road, Alphington, 826 Heidelberg Road, Alphington, 828 Heidelberg Road, Alphington, 130 Marshall Street, Ivanhoe. 2. Declare that the plaintiff and the defendant be the joint beneficial owners of 549 Coles Myer shares and 100,000 units in the Global Property Fund. 3. Order that on or before 1 December 2000 the plaintiff do execute a registrable instrument of transfer of her interest in the said land to the defendant and deliver the same to the plaintiff's solicitors in exchange for a bank cheque in the sum of $418,500. 4. Liberty to apply generally in addition to leave to make submissions as to the appropriate form of the orders in this case. I will hear submissions as to costs. 5. I will also hear submissions as to whether an accounting should be ordered as to the 1/8th share held in Dimax by the plaintiff.
Burns
Chazan [2000] VSC 328
(1999) 73 ALJR 839
(1986) 161 CLR 513