For example, a marriage-like relationship can exist in the absence of sexual relations, public displays of affection, a shared bed, shared holidays, or economic integration: Yakiwchuk v. Oaks, 2003 SKQB 124 at para. 10, cited with approval in Austin at para. 58. Moreover, an unhappy or unhealthy relationship can still be marriage-like. It is the general nature of the relationship, and not its quality, that governs the determination: J.J.G. v. K.M.A., 2009 BCSC 1056 at para. 71. The case of J.A.B. v. H.W.C., 2008 BCSC 644, is illustrative. There, it was found that the parties’ marriage-like relationship was dysfunctional and unhealthy for years before it ceased to be marriage-like: see, in particular, paras. 115-116.
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