LENNAN & LENNAN (No.2)

In *Lennan & Lennan (No.2)*, the Family Court of Australia considered a property settlement dispute between a husband and wife following a 12-year marriage. The central difficulty in resolving the matter was the husband's persistent failure to comply with his disclosure obligations regarding the extent of the marital property.

The primary legal issue before the Court was how to proceed with the property adjustment when the exact value and composition of the asset pool remained uncertain due to the husband's non-disclosure. This raised questions about the appropriate inferences to be drawn from such conduct and the impact of these inferences on the equitable distribution of property.

Egan J drew an adverse inference against the husband, concluding that his lack of transparency indicated that the undisclosed assets were likely substantial and that he had deliberately concealed them. Applying the principles of equitable distribution in family law, the Court made a substantial property adjustment order in favour of the wife, reflecting the adverse inference drawn from the husband's conduct.