In today’s society, de-facto relationships are not so straight forward and “modern relationships” challenge the traditional ideas of a relationship.

In Western Australia, the Family Court Act 1997 (“Family Court Act”) governs de-facto relationships. When determining whether a relationship is de-facto, the Court must decide whether the relevant couple were living in a “marriage-like relationship”. One of the difficulties the Court faces is determining what is “marriage-like” especially in today’s society.