What are the requirements for a spouse to retain a portion of her husband’s property as a result of their relationship?

As for the third requirement, the absence of any juristic reason for the enrichment, I am satisfied that, in Dickson J.’s words (at p. 181), this is a case … where one person in a relationship tantamount to spousal prejudices herself in the reasonable expectation of receiving an interest in property and the other person … freely accepts benefits conferred by the first person in circumstances where he knows or ought to have known of that reasonable expectation … and therefore “it would be unjust to allow the recipient of the benefit to retain it.” As Cory J. said in his separate concurring judgment in Peter v. Beblow, supra (at p. 1018 S.C.R., p. 358 R.F.L.), “there will be an absence of juristic reasons for the enrichment” when “a claimant is under no obligation, contractual, statutory, or otherwise, to provide the work and services to the recipient.” That is the case here.

There is a sufficient causal connection or link between the services rendered and the property in which the trust is claimed: in Sorochan v. Sorochan, 1986 CanLII 23 (SCC), [1986] 2 S.C.R. 38, 2 R.F.L. (3d) 225, Peter v. Beblow, supra, at p. 997 S.C.R., p. 343 R.F.L. The services of Ms Russ contributed to the acquisition and improvement of that property, and beyond that her activities contributed to the family enterprise as a whole.