© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2019] NSWCA 90
Court of Appeal (NSW)
2018-11-29
Macfarlan JA, Meagher JA, Kunc J, Hallen J, Macfarlan J
Original judgment source is linked above.
[Note: The Uniform Civil Procedure Rules 2005 provide (Rule 36.11) that unless the Court otherwise orders, a judgment or order is taken to be entered when it is recorded in the Court's computerised court record system. Setting aside and variation of judgments or orders is dealt with by Rules 36.15, 36.16, 36.17 and 36.18. Parties should in particular note the time limit of fourteen days in Rule 36.16.]
headnote [This headnote is not to be read as part of the decision] The appellants are two adult children of the first marriage of Richard Squire (the Deceased) who died unexpectedly on 29 April 2015. The respondent was the Deceased's second wife and is the executrix named in his will made on 21 March 2007. By that will, the Deceased left the whole of his estate to the respondent and if she did not survive him by 30 days, that estate was to be divided equally between his three children and the two children by her first marriage. Shortly before the Deceased's death, he and the respondent ended their relationship and took steps to effect a permanent separation, including by systematically dividing their assets. The Deceased made statements to his children about writing a new will to reflect his fundamentally changed circumstances. The principal asset of the marriage was a jointly held interest in a home unit, which was sold on 20 March 2015 with settlement occurring shortly after the Deceased's death. The Deceased's half-share of those proceeds is capable of being made the subject of a "notional estate" order under Succession Act 2006 (NSW), Ch 3 Pt 3.3. Upon the Deceased's death, the respondent became entitled by survivorship to the whole of the sale proceeds. The appellants applied under Succession Act 2006 (NSW), Ch 3 Pt 3.2, for family provision orders in the form of payments from that proposed notional estate of $85,000 each. The primary judge dismissed their claims, describing the respondent's claim as "superior" and finding that the Deceased had an ongoing obligation to make testamentary provision for the respondent as his "former" spouse. In those circumstances, the primary judge was not satisfied that the appellants had been left without adequate provision for their proper maintenance, education or advancement in life. The principal issues in the appeal were: (i) whether the primary judge erred in his assessment of the respondent's financial position. (ii) whether the primary judge erred in his finding that the respondent had not received a financial settlement. (iii) whether it was "reasonable" for the respondent to expect the Deceased to make a provision that would allow her to own an unencumbered property worth up to $600,000. (iv) whether the Court should conclude that adequate provision for the appellants was not made from the Deceased's estate. Held, allowing the appeal (per Meagher JA, Macfarlan JA and Simpson AJA agreeing): As to issue (i): (1) The primary judge did not err in his assessment of the respondent's financial position, which took account of her half-share of the sale proceeds and the superannuation benefit she had received upon the Deceased's death. The $120,000 advanced to her daughter was not an asset that she could readily draw on: [1], [22], [23], [47]. As to issue (ii): (2) By engaging in a deliberate and systematic division of their jointly held assets and liabilities, the Deceased and the respondent had agreed on a final albeit informal financial settlement which terminated any obligation of the Deceased to make any ongoing testamentary provision for the respondent's maintenance or advancement in life: [1], [29], [30], [47]. Lodin v Lodin [2017] NSWCA 327; Dijkhuijs (formerly Coney) v Barclay (1988) 13 NSWLR 639 applied. As to issue (iii): (3) Given their economic and social circumstances, the respondent could reasonably be expected to live in much more modestly priced permanent accommodation than an unencumbered property worth up to $600,000: [1], [31], [47]. As to issue (iv): (4) At the time of the Deceased's death, the natural objects of his testamentary bounty were his adult children. The nil provision for the appellants in the Deceased's last will was not adequate; adequate provision extended to the making of the provisions claimed; and the Deceased's half-share of the sale proceeds should be designated as notional estate to enable those claims to be satisfied: [1], [34], [36], [38], [47].
Overview
The reasoning of the primary judge
The issues in the appeal
Analysis of respondent's financial circumstances (grounds 2 and 3)
Significance of absence of any "financial settlement" (grounds 4(a) and 5(a))
Respondent's aspiration to own unencumbered home unit in Baulkham Hills (grounds 4(b), (c) and 5(b))
Reconsideration of the questions as to adequacy of provision
Costs
Conclusion
Amendments 01 May 2019 - addition of "notional" in [19] DISCLAIMER - Every effort has been made to comply with suppression orders or statutory provisions prohibiting publication that may apply to this judgment or decision. The onus remains on any person using material in the judgment or decision to ensure that the intended use of that material does not breach any such order or provision. Further enquiries may be directed to the Registry of the Court or Tribunal in which it was generated. Decision last updated: 01 May 2019
Squire
Squire
[1986] HCA 17
[1994] HCA 40
(1988) 13 NSWLR 639
(1936) 55 CLR 499
(1986) 161 CLR 513
(1962) 107 CLR 9
(1994) 181 CLR 201
(2005) 221 CLR 191
[1936] HCA 40