© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2004] VSC 66
Supreme Court of Victoria
2004-03-16
NETTLE J
Original judgment source is linked above.
"As has been seen however, the relationship between the parties in the present case was not merely a commercial one. It was a mixture of the commercial and the personal. The personal relationship provided the context and explains the content of the planned commercial venture. If the personal relationship had survived for years after the collapse of the commercial venture and the property had been unmistakenly devoted to serve solely as a mutual home, any assessment of what would and would not constitute unconscionable conduct would obviously be greatly influenced by the special considerations applicable to a case where a husband and wife or persons living in a "de facto" situation contribute, financially and in a variety of other ways, over a lengthy period to the establishment of a joint home. In the forefront of those special considerations there commonly lies a need to take account of a practical equation between direct contributions in money or labour and indirect contributions in other forms such as support, home-making and family care. "(Emphasis added)
"These decisions establish in unambiguous terms that, when determining whether it is unconscionable for one party to a de facto relationship to retain the sole beneficial ownership of property acquired in the course of the relationship, regard will be had to the manner in which the parties have conducted their relationship and the contributions each have made. When assessing their respective contributions, regard will be had to non-financial contributions as well as to financial contributions. The latter proposition is clear from the references to the `practical equation between direct contributions in money or labour and indirect contributions in other forms such as support, homemaking and family care' in Muschinski v Dodds (at 622) and in the reference to `contributions either financially or in kind' in Baumgartner (at 150). The principle that regard will be had to non-financial contributions when considering the division of property on the dissolution of a marriage has been affirmed on more than one occasion: see Mallet v Mallet [1984] HCA 21; (1984) 156 CLR 605 at 623 per Mason J and the cases there cited. In that passage Mason J noted that a wife's contribution as a homemaker should be recognised in a substantial, and not merely token, way, this being a recognition of the fact that, by her attention to the home and the children, the wife frees her husband to earn income and acquire assets: see also Deane J (at 640) and Dawson J (at 646). These observations were made when considering the effect of s79 of the Family Law Act, 1975 (Cth), which directs the Family Court, when altering interests in property, to have regard to the contribution made in the capacity of homemaker or parent. That principle was reaffirmed by Mason CJ, Deane and McHugh JJ in Singer v Berghouse [No2] [1994] HCA 40; (1994) 181 CLR 201 at 212-213 in these terms:
`As recent cases in this Court have made plain (eg Mallet v Mallet (at 623), it is important that the courts do not disregard or discount the non-financial contributions made to the property and finances of the party to a marriage or marriage-like relationship, such as the contributions made by parties as homemakers and parents, which are not directly productive of a monetary return.'
As I understand them, these remarks have a general application and are not, as the trial judge believed, limited to claims for what used to be called testator's family maintenance. That is evident not only from the manner in which the observations were made but, in particular, by the reference to Mallet . The reference to recent cases stating that non-financial contributions are relevant in marriage-like relationships is plainly a reference to Muschinski v Dodds and Baumgartner. Thus, Singer v Berghouse affirms the authority of those decisions."
"Equity favours equality. As Mason CJ, Wilson and Deane JJ said (at 149) in Baumgartner where the parties have lived together for years and have pooled their resources `there is much to be said for the view that they should share the beneficial ownership equally as tenants in common, subject to adjustment to avoid any injustice which would result if account were not taken of the disparity between the worth of their individual contributions either financially or in kind'. In Baumgartner their Honours thought an adjustment was called for. They declared the interests of the parties in the proportions of 55 per cent and 45 per cent. They also made adjustments to take account of moneys paid by the parties."
"In Muschinski, the court decided that each party should receive, from the house, the amount of their respective contributions and that the residue should be held for them in equal shares. In Baumgartner, the approach was, at least in terms, somewhat different. The approach involved three stages. First, their Honours saw the purpose of the joint relationship in that case as being or including `to provide accommodation for themselves and their children': at 149. They saw their `earnings' as having been `pooled for the purposes of that relationship': at 149. And, the relationship having failed, they saw it as inequitable that the house, `financed in part through the pooled funds': at 149; should be held by Mr Baumgartner alone."
"In order to evaluate the particular contribution the court is, in my opinion, required carefully to examine the role played by the person who claims to have contributed as a homemaker and parent. Obviously, where a woman has, over a long period, assumed virtually all the responsibility of maintaining the home and bringing up the children, has done so in a responsible and energetic manner, and has devoted most of her time to doing that and thus freed her partner to earn income to be used for the general betterment of the family, her contribution would have to be regarded as substantial and significant. Whether her contribution should be regarded as less than, equal to, or greater than the financial contribution by the wage-earning partner must depend upon the circumstances of the case, which will undoubtedly include the length of the relationship, the nature of the wage-earner's contributions and the care, devotion and services of the homemaker."
[9] [1961] VicRp 41; [1961] VR 264 at 268
[12] Skene v Dale [1990] VicRp 53; [1990] VR 605 at 613,per Kaye J; see also Kalejs v Minister for Justice & Customs (2001) 111 FCR 442; [2001] FCA 1769 at [20]
[13] cf Agtrack v Hatfield [2003] VSCA 6
[14] Although it has been held that it is permissible to refer to s.285 as a form of guidance in determining what is equitable: see Parij v Parij [1997] SASC 6771; (1987) 72 SASR 153 at 166 -7, per Debelle J
[15] (1989) 17 NSWLR 343 at p.353.F; See also Hibberson v George (1989) 12 Fam LR 725 at p.743 per McHugh JA
[16] [1985] HCA 78; (1985) 160 CLR 583 at 622
[17] [1997] SASC 6771; (1997) 72 SASR 153 at 163
[18] cf Black v Black (1991) 15 Fam LR 10
[19] (1991) 15 Fam LR 109 at 117
[20] $500 + $1500 + $7,200 +$5,500 = $14,700
Read
Nicholls [2004] VSC 66
"...it is now well settled that there are circumstances in which a court of equity will intervene to declare the existence of a proprietary interest in a family home on the part of spouse or de facto partner, and the unifying principle underlying the cases where such intervention is regarded as appropriate is that in the circumstances of the case, and in accordance with equitable doctrines, it would be unconscionable on the part of the person against whom the claim is set up to refuse to recognise the existence of the equitable interest: Baumgartner v Baumgartner [1987] HCA 59; (1987) 164 CLR 137 at 147 per Mason CJ, Wilson and Deane JJ. The most common case of intervention of that kind to be found in the law reports is the case where the person in whose favour a constructive trust is found has, directly or indirectly, made a financial contribution towards the cost of acquiring, improving, or maintaining the property in question. Lord Diplock's discussion of the principles relevant to such a case in Gissing v Gissing [1970] UKHL 3; [1971] AC 886 at 905-10 appears now to be generally accepted by the courts in England as correctly stating the law. It is of interest to note the general proposition with which his Lordship introduced his discussion of the particular problem that arises where both spouses have contributed, directly or indirectly, to the cost of a matrimonial home..."
(1987) 164 CLR 137
(1984) 156 CLR 605
(1994) 181 CLR 201
(1985) 60 CLR 583
(1989) 17 NSWLR 343
(1997) 72 SASR 153
(1979) 22 SASR 139
(1989) 16 NSWLR 16
(2001) 111 FCR 442
(1987) 72 SASR 153
(1989) 12 Fam LR 725
(1985) 160 CLR 583
(1991) 15 Fam LR 10
(1991) 15 Fam LR 109