legislation at that time, a common law wife was not legally entitled to a share in any property owned by her husband. Therefore, any remedy for Becker would have to be based on the wholly equitable doctrine of constructive trust and principles of unjust enrichment. Reasons of the court Dickson J. set out three requirements for finding a constructive trust. There must be 1) an enrichment; 2) a corresponding deprivation; and 3) the absence of any juristic reason for the enrichment. In this case, Dickson found that the requirements were satisfied and held that Becker was entitled to half the assets. He held that: "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 in the relationship freely accepts benefits conferred by the first person in circumstances where he knows or ought to have known of that reasonable expectation, it would be unjust to allow the recipient of the benefit to retain it." Aftermath After the ruling in Becker's favour, Pettkus avoided paying out the money owed. When Pettkus's assets were finally liquidated, Becker's lawyer took most of the share, and left her with nothing. In a tragic turn of events, Becker committed suicide with a gunshot to the head on November 5, 1986. The suicide note accused the legal system of forcing her to do it. Several provinces subsequently amended their family relations legislation to include common law relationships as to the division of family assets. (Under the Canadian Constitution divorce is governed by federal statute, property by provincial statute. Pettkus with its new version of the constructive trust was soon adopted in Australia. The High Court of Australia enunciated a similar rule in Muschinski v Dodds (1985) 160 CLR 583 and Baumgartner v Baumgartner (1987) 164 CLR 137, albeit with the caveat that the complaining party must not have been responsible for the breakdown of the relationship. See also Murdoch v. Murdoch a similar controversial matrimonial property case. External links Full text of Ontario Court of Appeal decision at CanLII Canadian family case law Supreme Court of Canada cases 1980 in Canadian case law Unjust enrichment