Further, the analysis concerning violence is typically conducted in the context of whether the continuation of joint cohabitation in the matrimonial home is practical: Kutlesa v. Kutlesa (2008), 2008 CanLII 13187 (ON SC), 52 R.F.L. 164 (S.C.J.). In this case, the husband has no desire to cohabitate with the wife in the matrimonial home.
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