What is the difference between enrichment and deprivation in the context of a claim for full-time devotion?

Ontario, Canada


The following excerpt is from Taylor v. Guindon, 2005 CanLII 25894 (ON SC):

The case law suggests that enrichment and deprivation are two sides of the same coin. Where one is found normally the other will also be found. In Sorochan v. Sorochan, 1986 CanLII 23 (SCC), [1986] 2 S.C.R. 38, Dickson C.J. wrote at para. 12-15: [I]t is clear that the respondent derived a benefit from the appellant’s many years of labour in the home and on the farm …On the other side of the coin, the labour done by [the appellant] during those forty-two years constituted for her a corresponding deprivation…Moreover, the case law indicates that the full-time devotion of one’s labour and earnings without compensation can readily be viewed as a deprivation.

In Peter v. Beblow, 1993 CanLII 126 (SCC), [1993] 1 S.C.R. 980 at para. 73, Cory J. agreed with this reasoning. He held: As a general rule, if it is found that the defendant has been enriched by the efforts of the plaintiff there will, almost as a matter of course be deprivation suffered by the plaintiff…Particularly in a matrimonial or long term common law relationship it should, in the absence of cogent evidence to the contrary, be taken that the enrichment of one party will result in a deprivation of the other.

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