Goodbye Bundle of Rights. Hello constructive trusts.
In the days when Parliament didn’t recognise de facto unions (ie before 2002) the courts used constructive trusts to give ‘deserving’ parties access to ‘relationship wealth’. Lankow v Rose  1 NZLR 277 was the case they relied on. In it, Justice Tipping held that a constructive trust would be declared if a claimant could show:
1. “Contributions, direct or indirect, to the property in question.
2. The expectation of an interest therein.
3. That such expectation is a reasonable one.
4. That the defendant should reasonably expect to yield the claimant an interest.”
The development of significance came with Prime v Hardie (2002) 1 NZTR 12-008 where Justice Salmon held that a constructive trust could be imposed over the assets of an express trust.