In Moge v. Moge, 1992 CanLII 25 (SCC), [1992] 3 S.C.R. 813, (at pp. 861-862), L’Heureux-Dubé J. discussed the historical disadvantage suffered by women as a consequence of marriage and its breakdown: Women have tended to suffer economic disadvantages and hardships from marriage or its breakdown because of the traditional division of labour within that institution. Historically, or at least in recent history, the contributions made by women to the marital partnership were non-monetary and came in the form of work at home, such as taking care of the household, raising children, and so on. ... once the marriage dissolves, the kinds of non-monetary contributions made by the wife may result in significant market disabilities. The sacrifices she has made at home catch up with her and the balance shifts in favour of the husband who has remained in the workforce and focussed his attention outside the home. In effect, she is left with a diminished earning capacity and may have conferred upon her husband an embellished one.
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