In 2018, a Trial Judge of the Federal Circuit Court of Australia made Orders for a property settlement, in favour of the de facto husband. The outcome provided for the de facto husband to receive a significant adjustment of 75% of the pool of assets, and the de facto wife the remaining 25%.

In Whiton & Dagne [2019] FamCAFC 192, the Full Court of the Family Court overturned the decision of the Trial Judge, referring to his decision as a “‘leap from words to figures” insufficiently heralded by any reasoning”.