The Full Court held in Kennon [1997] FamCA 27 that:
“… where there is a course of violent conduct by one party towards the other during the marriage which is demonstrated to have had a significant adverse impact upon that party’s contributions to the marriage or … to have made his or her contributions significantly more arduous that they ought to have been, that is a fact which a trial judge is entitled to take into account in assessing the party’s respective contributions within Section 79.”
It should be noted that any potential adjustment must be considered holistically, together with all other factors and contributions as set out in Section 79 of the Family Law Act.
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