What is the effect of a court order to return a husband's separate property to his estranged wife?

Even prior to enactment of the Family Law Act, courts fashioned remedies to enforce their orders. Discussing a lien imposed on a husband's separate property to secure payment to wife, the court in Jackson v. Jackson (1949) 93 Cal.App.2d 101, 208 P.2d 997 emphasized it did not secure "her allotted share of the community property." (Id., at p. 108, 208 P.2d 997.) Nor in this case does the court's order to return husband's separate property or pay its value place any burden on her. She need only return the property as ordered. In the event she does not, she owes a separate obligation, "distinct from the preceding division of community properties. It is merely a separate equitable adjustment of the obligations of the spouses ...." (Ibid.) We find no error in the conditional order to return the property or be charged for its equivalent, as the court may fashion an order to effect its decree. ( 4380.) "A special benefit of a system which allows for equitable considerations, especially in the family law field, is to afford the judge before whom the litigants appear, subject to applicable legal principles, the opportunity to fashion a remedy which achieves a just result. While critics may claim this results in inconsistency, we believe the strength of the judicial system is enhanced when the judiciary possesses the ability in family law cases to tailor a remedy to fit the circumstances of the individual litigants before the court." (In re Marriage of Hug (1984) 154 Cal.App.3d 780, 794, 201 Cal.Rptr. 676.)