Carruthers v Manning

In the case of Carruthers v Manning, the dispute arose between the plaintiff, Carruthers, and the defendant, Manning, concerning the equitable distribution of property interests within a de facto relationship. The matter was heard in the Family Court of Australia, where the plaintiff sought an adjustment of property interests on the grounds of unjust enrichment and equitable estoppel, among other claims. Carruthers alleged that despite being in a de facto relationship with Manning, she had not received her fair share of the property's value due to Manning's alleged promises of financial support and accommodation for life, which Carruthers had relied upon to her detriment.

The legal issues central to the case involved determining whether a constructive trust existed over the property, whether there was a common intention to share property interests, and if Manning's actions constituted unconscionability. Additionally, the court had to consider if Carruthers' reliance on Manning's promises created an equitable estoppel or proprietary estoppel that Manning was estopped from denying Carruthers' claim to the property. The court also needed to weigh the direct and non-financial contributions made by Carruthers to the relationship and the property.

The Family Court found in favour of Carruthers, acknowledging that she had made significant financial and non-financial contributions to the relationship and the property. The court held that Manning had promised to provide for Carruthers financially and in terms of accommodation, which Carruthers had reasonably relied upon. Consequently, the court deemed it just and equitable to adjust the property interests in favour of Carruthers. The court concluded that Carruthers' reliance on Manning's promises created an equitable estoppel, and Manning was estopped from denying Carruthers' entitlement to the property. The court ordered that the property interests be adjusted to reflect a fair distribution between the parties, recognising Carruthers' contributions and reliance on the promises made by Manning.