Subsequently, in Nedelak v. Nedelak, Skipp L.J.S.C. said: “A distinction has sometimes been made between a wife who has actually contributed to the estate of the husband in the sense of something more than the normal functions of a wife and mother, including working for wages which were invested in the property, a farm wife assisting in pulling stumps, driving a tractor or other manual work, and involvement in a business which may have been carried on by the husband with accounting or administrative contributions. “Surely a wife who has been faithful to her duties to a marriage, a person sometimes described as an ordinary housewife, and who has cared for her children and husband throughout the normal vicissitudes of marriage can be ‘entitled to property’. And here I add the usual disclaimer that each case must be decided on its own facts. To express it negatively a wife is not a person not entitled to property within the meaning of section 8 because she cannot be proved to have made a contribution over and above her normal duties as a housewife.”
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