What is the meaning of the term “indirect contribution” in s. 59 of the Statutory Guidelines for Divorce and Divorce?

In terms of the meaning of “indirect contribution” in s. 59, it can usually be inferred that a traditional housewife and mother has contributed indirectly by accruing savings to the benefit of her husband and his business interests. In some “unique cases” however there will simply be no connection between the supposed “savings” and the business activities (Noble v. Noble, [1992] B.C.J. No. 1748 (S.C.)). In a case where the husband has not contributed to the acquisition, maintenance, or enhancement of the assets in question, it is unlikely that the courts will go on to find that even the most effective wife and mother has contributed indirectly to those assets herself.

This is particularly relevant in the situation of an inheritance or gift. Izard v. Izard, [2004] B.C.J. No. 2356 (S.C.), is one example where the court found that the husband made no direct or indirect contribution to “the acquisition or operation of the Oak Tree shares” he received as a gift, and it followed that the wife did not make a contribution either.