What is the current state of the law on non-compensatory support for spousal support?

Martinson J. went on to note that Bracklow v. Bracklow, 1999 CanLII 715 (SCC), [1999] 1 S.C.R. 420 [Bracklow], expanded the basis for spousal support by recognizing non-compensatory support. The non-compensatory approach is based upon the theory that primary responsibility falls on the former spouse, rather than the government, to provide for his or her former partner. This approach views marriage as a relationship of interdependence and one of permanence, challenging the notion that spouses can cleanly or easily disentangle themselves from the relationship. In certain instances where self-sufficiency is not possible, or compensation is not applicable, "a support obligation may nonetheless flow from the marriage relationship itself": Bracklow at para. 37.