The High Court has held that contribution within a marriage is not limited to direct financial payment towards the acquisition of assets, but also indirect support that facilitates the purchase of property, thereby giving rise to a claim in matrimonial property.

In making this determination, the court found that a woman, who used her salary to meet household expenses, indirectly enabled her husband to save, service loans, and acquire property, thereby establishing a beneficial interest in assets such as plots of land, a motor vehicle, and a matrimonial home.