“To obtain an award for unjust enrichment arising from a joint family venture, a claimant must show two things: first, a joint family venture; and second, a link between the claimant’s contribution to the venture and the accumulation of assets or wealth: see Kerr v. Baranow, at para. 87.
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In Kerr v. Baranow, Cromwell J. said that to be entitled to a remedy for unjust enrichment arising from a joint family venture, the claimant must show “a link between his or her contributions to it and the accumulation of assets and/or wealth” (at para. 100). In other words, the family’s accumulation of wealth must have resulted from the parties’ mutual efforts. Cromwell J. wrote, at para. 102:
Once the claimant has established his or her contribution to a joint family venture, and a link between that contribution and the accumulation of wealth, the respective contributions of the parties are taken into account in determining the claimant’s proportionate share.”