What is the current state of the law on marriage benefits?

In Burgess, Devlin J. (as he then was) reviews various authorities and gives some examples which fall on one side of the line or the other. The result, in my opinion, is that the damages are confined solely to the value of the services actually contributed to the claimant. The benefit must be one that can properly be attributed to the relationship of husband and wife. It must be derived solely from that relationship: Malyon v. Plummer, [1964] 1 Q.B. 330 at 341, [1963] 2 W.L.R. 1213, [1963] 2 All E.R. 344.