What is the test for “unconscionable conduct” in divorce law?

In Levan v. Levan, Justice Backhouse writes that, "[u]nconscionability" is a much more difficult test to meet than "fairness" and as a result, the courts have only minimal discretion to order anything other than an equal division of family property. Unconscionable conduct has been defined as, among other things, conduct that is harsh and shocking to the conscience, repugnant to anyone's sense of justice, or shocking to the conscience of the court.”