A Comparative View of Property Rights in De Facto Relationships : Are We All Driving in the Same Direction?

Property disputes between de facto partners have been the focus of much attention in England, Australia, Canada and New Zealand. In this paper, the author compares the approaches adopted in each of these countries for dealing with such disputes. The author concludes that English courts have given common intention a technical meaning by requiring evidence of an implied agreement between the parties to share the property, while the courts in Canada, Australia and New Zealand prefer a more lenient approach