These two cases, and many others before them, resulted in legislation in every province to insure that contributions by spouses other than money contributions, be recognized as entitling each spouse to a fair division of matrimonial property upon marriage breakdown. While in Saskatchewan under our Matrimonial Property Act the spouse asking for a division of property need no longer recite detailed lists of money, labour, time and effort put into the marriage relationship, I am nevertheless of the view that the Act contemplates the existence of a marriage relationship to which both husband and wife contributed, and did not contemplate a marriage relationship to which neither contributed much more than occasional sex, and occasional help to the other, she as hostess infrequently, he in doing some errands, such as might be expected from good friends or neighbours. The “presumption” of joint contribution referred to in Farr v. Farr, supra, seems to me to have been rebutted in this case.
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