What constitutes a relationship analogous to marriage?

Regard must also be had to the changing view of marriage and its obligations, as reflected in the Divorce Act and the authorities, particularly the nature of the support obligation. In Miron v. Trudel, supra, Madam Justice L'Heureux-Dubé suggested (at 468 S.C.R.) that a relationship analogous to marriage would be a relationship of "some degree of publicly acknowledged permanence and interdependence". In the following paragraph, she acknowledged that "[w]hat constitutes a relationship analogous to marriage is, of course, potentially a subject of considerable debate".

What constitutes a formal marriage is equally open to debate. For Douglas J. in Grizwold v. Connecticut, 381 U.S. 479 (1965): Marriage is a coming together for better or for worse, hopefully enduring, and intimate to the degree of being sacred. It is an association that promotes a way of life, not causes; a harmony in living, not political faiths; a bilateral loyalty, not commercial or social projects. Yet it is an association for as noble a purpose as any involved in our prior decisions. Mr. Justice Gonthier quoted these words in his reasons in Miron v. Trudel in support of his view that marriage rests on a contractual basis to which the law attaches certain rights and obligations, as he explained at 450: The decision to marry includes the acceptance of various legal consequences incident to the institution of marriage, including the obligation of mutual support between spouses and the support and raising of children of the marriage.