Nova Scotia V. Walsh Case Study

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This paper will provide a summary analysis of the Nova Scotia (Attorney General) v Walsh case. This paper will argue that Justice L’Heureux-Dubé’s dissent concerning the discrimination of unmarried cohabiting heterosexual couples based upon marital status is the most convincing because it addresses the similarities between married and unmarried cohabiting heterosexual couples in terms of their needs following the breakdown of a relationship. Both parties have formed an economic interdependence that requires resolution through the division of their acquired assets. This will be established through the analysis of the facts, legal issues and judicial reasonings presented by Justice Bastarache, Justice Gonthier and Justice L’Heureux-Dubé.
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In 1999, the Supreme Court of Nova Scotia determined that the exclusion of common law heterosexual couples from the definition of spouse in section 2(g) of the Matrimonial Property Act, was not discriminatory and that even if it was found to be, it was saved under section 1 of the Charter. Marital status is not a protected ground under section 15(1) of the Charter. In 2000, the Nova Scotia Court of Appeal determined that the Crown had failed to demonstrate how the exclusion of common law heterosexual spouses from the provisions of the MPA was pressing and substantial. Therefore, the provisions of the MPA pertaining to the exclusion of common law relationships was found to be infringing upon section 15(1) of the Charter and this infringement could not be demonstrably justified in a free and democratic society under section 1 of the Charter. The appeal was …show more content…

The MPA is not discriminatory in its extension solely to married couples, for it does not deprive common law spouses of the dignity and liberty to choose alternative forms of cohabiting unions. The choice of cohabiting common law spouses to not pursue marriage can be attributed to numerous factors that must be respected in light of their personal autonomy. They have the liberty to make this choice. In order to determine whether there was a violation of section 15 of the Charter, the majority applied the Law test, which is a three-stage approach that was set out in Law v Canada. When considering whether the exclusion of non-married couples from the MPA was discriminatory, so as to violate section 15 of the Charter, the majority relied on the notion of the freedom of choice for alternative family forms. The MPA acknowledges this freedom of choice to get married, and allows for consenting married couples the opportunity to opt out. By extending the protections afforded in the MPA to unmarried cohabitants, it infringes upon an individual’s freedom of choice for their lifestyle. It is unjust for the state to impose this matrimonial property regime on persons who have chosen not to marry. An individual’s freedom to choose an alternative family form needs to be respected and legitimated by the state through

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