Justice Voith observed that as between husbands and wives, the presumption has been consistently questioned and steadily eroded for nearly fifty years, based as it appears to be, on the outmoded theory that wives are economically dependent on their husbands (para. 115). In Zhu v. Li, 2009 BCCA 128, for example, Neilson J.A. commented that there was much support for the view that the presumption had lost its force in the contemporary matrimonial context, based on the same observation:
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