{"id":7207,"date":"2026-02-27T00:21:23","date_gmt":"2026-02-27T00:21:23","guid":{"rendered":"https:\/\/somia.com.au\/how-to-determine-the-existence-and-duration-of-a-de-facto-relationship-when-a-party-maintains-a-concurrent-secondary-relationship\/"},"modified":"2026-03-09T05:57:36","modified_gmt":"2026-03-09T05:57:36","slug":"how-to-determine-the-existence-and-duration-of-a-de-facto-relationship-when-a-party-maintains-a-concurrent-secondary-relationship","status":"publish","type":"post","link":"https:\/\/somia.com.au\/zh\/how-to-determine-the-existence-and-duration-of-a-de-facto-relationship-when-a-party-maintains-a-concurrent-secondary-relationship\/","title":{"rendered":"How to determine the existence and duration of a de facto relationship when a party maintains a concurrent secondary relationship?"},"content":{"rendered":"

\u4e8b\u5b9e\u5a5a\u59fb\u5173\u7cfb\u7ba1\u8f96\u6743\u7ea0\u7eb7\uff1a\u5982\u679c\u4e00\u65b9\u4f34\u4fa3\u58f0\u79f0\u8be5\u5173\u7cfb\u5728 2009 \u5e74 3 \u6708 1 \u65e5\u4e4b\u524d\u7ed3\u675f\uff0c\u5bb6\u5ead\u6cd5\u9662\u80fd\u5426\u53d7\u7406\u8d22\u4ea7\u6848\u4ef6\uff1f<\/span><\/span><\/h3>\n

\u672c\u6587\u4ee5\u6fb3\u5927\u5229\u4e9a\u771f\u5b9e\u53f8\u6cd5\u6848\u4f8b Grohl & Acland [2018] FamCA 732\uff08\u6848\u5377\u53f7 WOC 692 of 2016\uff09\u4e3a\u57fa\u7840\uff0c\u5256\u6790\u4e86\u6cd5\u9662\u5728\u8bc1\u636e\u548c\u6cd5\u5f8b\u65b9\u9762\u7684\u5224\u51b3\u8fc7\u7a0b\u3002\u6587\u7ae0\u5c06\u590d\u6742\u7684\u53f8\u6cd5\u63a8\u7406\u8f6c\u5316\u4e3a\u6e05\u6670\u6613\u61c2\u7684\u5173\u952e\u70b9\u5206\u6790\uff0c\u5e2e\u52a9\u8bfb\u8005\u628a\u63e1\u4e89\u8bae\u6838\u5fc3\uff0c\u7406\u89e3\u5224\u51b3\u903b\u8f91\uff0c\u505a\u51fa\u66f4\u7406\u6027\u7684\u8bc9\u8bbc\u9009\u62e9\uff0c\u5e76\u4e3a\u4e0d\u540c\u80cc\u666f\u7684\u8bfb\u8005\u63d0\u4f9b\u6848\u4f8b\u8d44\u6e90\uff0c\u4ee5\u4f9b\u5b9e\u9645\u7814\u7a76\u4e4b\u7528\u3002<\/span><\/span><\/p>\n

\u7b2c\u4e00\u7ae0\uff1a\u6848\u4f8b\u6982\u8ff0\u53ca\u6838\u5fc3\u4e89\u8bae<\/span><\/span><\/strong><\/h4>\n
\u57fa\u672c\u4fe1\u606f<\/span><\/span><\/strong><\/h6>\n
    \n
  • \u5ba1\u7406\u6cd5\u5ead\uff1a\u6fb3\u5927\u5229\u4e9a\u5bb6\u5ead\u6cd5\u9662\uff08\u4f4d\u4e8e\u5e15\u62c9\u9a6c\u5854\uff0c\u5728\u5e03\u91cc\u65af\u73ed\u5ba3\u5224\uff09<\/span><\/span><\/li>\n
  • \u4e3b\u5ba1\u6cd5\u5b98\uff1a\u5361\u9c81\u6cd5\u5b98<\/span><\/span><\/li>\n
  • \u8bc9\u8bbc\u4e8b\u7531\uff1a\u6839\u636e 1975 \u5e74\u300a\u8054\u90a6\u5bb6\u5ead\u6cd5\u300b\u63d0\u51fa\u7684\u6d89\u53ca\u4e8b\u5b9e\u5a5a\u59fb\u5173\u7cfb\u58f0\u660e\u7684\u5bb6\u5ead\u6cd5\u7533\u8bf7\uff0c\u4ee5\u786e\u5b9a\u5728\u9884\u671f\u8d22\u4ea7\u5206\u5272\u8bc9\u8bbc\u4e2d\u7684\u7ba1\u8f96\u6743\u3002<\/span><\/span><\/li>\n
  • \u5224\u51b3\u65e5\u671f\uff1a2018\u5e749\u670814\u65e5<\/span><\/span><\/li>\n
  • \u6838\u5fc3\u5173\u952e\u8bcd\uff1a<\/span><\/span>\n
      \n
    • \u5173\u952e\u8bcd1\uff1a\u771f\u5b9e\u5224\u51b3\u6848\u4f8b<\/span><\/span><\/li>\n
    • \u5173\u952e\u8bcd 2\uff1a\u4e8b\u5b9e\u5173\u7cfb<\/span><\/span><\/li>\n
    • \u5173\u952e\u8bcd 3\uff1a\u7ba1\u8f96\u6743<\/span><\/span><\/li>\n
    • \u5173\u952e\u8bcd 4\uff1a1975 \u5e74\u300a\u8054\u90a6\u5bb6\u5ead\u6cd5\u300b\u7b2c 4AA \u6761<\/span><\/span><\/li>\n
    • \u5173\u952e\u8bcd 5\uff1a\u7b2c 90RD \u6761\u58f0\u660e<\/span><\/span><\/li>\n
    • \u5173\u952e\u8bcd 6\uff1a\u7b2c 90SM \u6761\u8d22\u4ea7\u5206\u5272\u9014\u5f84\uff08\u7ba1\u8f96\u4e8b\u5b9e\uff09<\/span><\/span><\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
      \u80cc\u666f<\/span><\/span><\/strong><\/h6>\n

      \u7533\u8bf7\u4eba\u4e0e\u7b54\u8fa9\u4eba\u6709\u7740\u957f\u8fbe\u6570\u5341\u5e74\u7684\u590d\u6742\u4e2a\u4eba\u7ecf\u5386\u3002\u4ed6\u4eec\u80b2\u6709\u4e24\u4e2a\u5b69\u5b50\uff0c\u5e76\u66fe\u591a\u5e74\u5171\u540c\u751f\u6d3b\u3002\u7136\u800c\uff0c\u4ed6\u4eec\u7684\u5173\u7cfb\u5e76\u975e\u4e00\u5e06\u98ce\u987a\u3002\u671f\u95f4\u7ecf\u5386\u4e86\u5206\u5c45\u3001\u6240\u8c13\u7684\u590d\u5408\u3001\u9519\u7efc\u590d\u6742\u7684\u611f\u60c5\u7ea0\u845b\uff0c\u4ee5\u53ca\u5bf9\u5f7c\u6b64\u65e5\u5e38\u751f\u6d3b\u771f\u5b9e\u9762\u8c8c\u7684\u79cd\u79cd\u8bf4\u6cd5\u3002<\/span><\/span><\/p>\n

      \u5bfc\u81f4\u8fd9\u573a\u7ea0\u7eb7\u6700\u7ec8\u8bc9\u8bf8\u6cd5\u5ead\u7684\uff0c\u5e76\u975e\u4ec5\u4ec5\u662f\u5173\u4e8e\u611f\u60c5\u3001\u8eab\u4efd\u8ba4\u540c\u6216\u9053\u5fb7\u8fc7\u9519\u7684\u4e89\u8bba\uff0c\u800c\u662f\u5173\u4e8e\u6cd5\u5f8b\u7ba1\u8f96\u6743\u7684\u4e89\u8bae\uff1a\u6cd5\u9662\u662f\u5426\u6709\u6743\u53d7\u7406\u540e\u6765\u7684\u8d22\u4ea7\u5206\u5272\u8bf7\u6c42\u3002\u8fd9\u4e00\u5173\u952e\u95ee\u9898\u53d6\u51b3\u4e8e\u53cc\u65b9\u662f\u5426\u4ee5\u4f34\u4fa3\u8eab\u4efd\u5171\u540c\u751f\u6d3b\uff0c\u4ee5\u53ca\u81f3\u5173\u91cd\u8981\u7684\u662f\uff0c\u8fd9\u6bb5\u5173\u7cfb\u662f\u5426\u5728\u6cd5\u5b9a\u622a\u6b62\u65e5\u671f\u524d\u5f7b\u5e95\u7834\u88c2\u3002<\/span><\/span><\/p>\n

      \u56e0\u6b64\uff0c\u672c\u6848\u53d8\u6210\u4e86\u4e00\u573a\u96c6\u4e2d\u5ba1\u7406\u4e00\u4e2a\u95ee\u9898\u7684\u5ba1\u5224\uff1a\u53cc\u65b9\u5173\u7cfb\u5728\u65f6\u95f4\u957f\u6cb3\u4e2d\u7684\u771f\u5b9e\u6027\u8d28\uff0c\u800c\u8fd9\u5e76\u975e\u9760\u53e3\u53f7\uff0c\u800c\u662f\u9760\u8bc1\u636e\u6765\u8bc1\u660e\u3002<\/span><\/span><\/p>\n

      \u6838\u5fc3\u4e89\u8bae\u4e0e\u7d22\u8d54<\/span><\/span><\/strong><\/h6>\n
        \n
      • \u7533\u8bf7\u4eba\u804c\u4f4d\uff08\u5bfb\u6c42\u6551\u6d4e\uff09\uff1a<\/span><\/span>\n
          \n
        • \u58f0\u660e\u5728\u76f8\u5173\u671f\u95f4\u5b58\u5728\u4e8b\u5b9e\u5a5a\u59fb\u5173\u7cfb\uff0c\u5e76\u5728 2009 \u5e74 3 \u6708 1 \u65e5\u4e4b\u540e\u7ec8\u6b62\uff0c\u4f7f\u6cd5\u9662\u80fd\u591f\u5bf9\u8d22\u4ea7\u5206\u5272\u7533\u8bf7\u884c\u4f7f\u7ba1\u8f96\u6743\u3002<\/span><\/span><\/li>\n<\/ul>\n<\/li>\n
        • \u7b54\u8fa9\u4eba\u7684\u7acb\u573a\uff1a<\/span><\/span>\n
            \n
          • \u4e00\u4efd\u8303\u56f4\u8f83\u7a84\u7684\u58f0\u660e\u8fa9\u79f0\uff0c\u4e8b\u5b9e\u5a5a\u59fb\u5173\u7cfb\u4ec5\u5b58\u5728\u4e00\u6bb5\u6709\u9650\u7684\u65f6\u95f4\uff0c\u5e76\u4e14\u5f88\u65e9\u5c31\u7ed3\u675f\u4e86\uff0c\u56e0\u6b64\u6cd5\u9662\u5bf9\u8d22\u4ea7\u5206\u5272\u7ea0\u7eb7\u6ca1\u6709\u7ba1\u8f96\u6743\u3002<\/span><\/span><\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

            The legal focus question was therefore: did a de facto relationship exist during the later period, and did it end only in a way that preserved federal family law jurisdiction for property proceedings?<\/p>\n

            Chapter 2: Origin of the Case<\/strong><\/h4>\n

            The parties began their relationship as young adults. At an early stage, they lived in the Applicant\u2019s parents\u2019 home. That arrangement already carried a feature that later became important: their private life did not always look conventional from the outside. Even while living together, they maintained separate bedrooms for a time, yet still had a sexual relationship. This detail mattered because the statutory test does not require any single hallmark of coupledom, and apparently inconsistent living patterns can still form part of a genuine domestic partnership when assessed as a whole.<\/p>\n

            As the relationship progressed, the parties moved into shared accommodation and later jointly acquired real property. They became parents to two children born in close succession. Family life then faced significant stress, including the diagnosis of one child with autism and intellectual delay. The evidence described a period of intense strain, conflict, and unpleasant altercations.<\/p>\n

            During earlier years, the Applicant worked with the Respondent in a business connected to his family\u2019s farming operation. Later, her direct involvement ceased around the time of the first child\u2019s birth. The Respondent\u2019s business expanded and evolved over time. That expansion later sat behind the Respondent\u2019s practical concern about asset protection and the Applicant\u2019s suspicion that the jurisdiction dispute was being used as a shield against a property claim.<\/p>\n

            A critical turning point occurred when the Respondent commenced a relationship with another woman during the parties\u2019 initial cohabitation period. The evidence indicated that the Respondent left the Applicant and that, after separation, there were arrangements for child support and time with the children. A letter during this period indicated a desire to maintain a routine of alternate weekend time with the children.<\/p>\n

            The next decisive moment was the Respondent\u2019s return to the jointly owned home. The Applicant characterised that return as reconciliation: the Respondent sought a second chance, told her the other relationship had ended, and resumed life as before. The Respondent, by contrast, sought to characterise the return as a purely functional arrangement for the children, alleging that the parties lived separate lives.<\/p>\n

            That difference was not merely semantic. It was the factual hinge on which the Court\u2019s jurisdiction turned. The case therefore escalated into a hearing where the Court had to reconstruct a domestic reality from fragments: patterns of residence, finances, family rituals, and credibility under cross-examination.<\/p>\n

            Chapter 3: Key Evidence and Core Disputes<\/strong><\/h4>\n
            Applicant\u2019s Main Evidence and Arguments<\/strong><\/h6>\n
              \n
            • Residence narrative:\n
                \n
              • The Respondent returned to the jointly owned home and resumed shared domestic life, including sharing the master bedroom and living together as a couple.<\/li>\n<\/ul>\n<\/li>\n
              • Financial pattern evidence:\n
                  \n
                • Household money left routinely in a familiar manner, resembling pre-separation practice.<\/li>\n
                • The Respondent continued to pay major outgoings for the home and later only sought equal contributions after a specific later date.<\/li>\n<\/ul>\n<\/li>\n
                • Social and family life evidence:\n
                    \n
                  • Regular family activities: Sunday drives, Christmas celebrations, Mother\u2019s Day and Father\u2019s Day as a family, and routine rituals such as a weekly takeaway dinner tradition.<\/li>\n<\/ul>\n<\/li>\n
                  • Credibility support evidence:\n
                      \n
                    • Corroboration by witnesses, including the parties\u2019 child, about the nature of daily family life and domestic routines.<\/li>\n<\/ul>\n<\/li>\n
                    • Narrative about knowledge of the Respondent\u2019s other relationship:\n
                        \n
                      • The Applicant denied knowledge of an ongoing relationship and gave evidence of shock upon learning details later.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
                        Respondent\u2019s Main Evidence and Arguments<\/strong><\/h6>\n
                          \n
                        • \u201cSeparate lives\u201d narrative:\n
                            \n
                          • The Respondent asserted that after his return, the parties did not resume an intimate relationship, and he moved back for the children\u2019s welfare rather than reconciliation.<\/li>\n<\/ul>\n<\/li>\n
                          • Depiction of the Applicant\u2019s behaviour:\n
                              \n
                            • The Respondent sought to portray the Applicant as violent and unpredictable, claiming fear and protective measures.<\/li>\n<\/ul>\n<\/li>\n
                            • Reliance on administrative record:\n
                                \n
                              • A Centrelink note recording an enquiry said to suggest the parties lived separate lives and did not meet relevant relationship indicators.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
                                Core Dispute Points<\/strong><\/h6>\n
                                  \n
                                1. Whether the parties were living together as a couple on a genuine domestic basis after the Respondent returned to the jointly owned home.<\/li>\n
                                2. Whether any separation occurred on a final basis before 1 March 2009, defeating jurisdiction.<\/li>\n
                                3. Whether the Respondent led a \u201cdouble life\u201d, maintaining two households in substance, and whether that is legally compatible with a de facto relationship.<\/li>\n
                                4. Whether the Centrelink record should be treated as determinative or merely one piece of the evidentiary mosaic.<\/li>\n
                                5. Witness credibility: whether the Respondent\u2019s account could be accepted where it conflicted with contemporaneous patterns and the Applicant\u2019s corroborated narrative.<\/li>\n<\/ol>\n

                                  Chapter 4: Statements in Affidavits<\/strong><\/h4>\n

                                  Affidavits in family law are not merely storytelling documents. They are structured vehicles for converting lived experience into admissible evidence. The tactical value of an affidavit depends on internal consistency, alignment with external records, and the ability to withstand cross-examination.<\/p>\n

                                  In this case, the affidavit evidence functioned like competing maps of the same terrain:<\/p>\n

                                    \n
                                  • The Applicant\u2019s affidavit strategy:\n
                                      \n
                                    • Build a coherent chronology of cohabitation, reconciliation, and domestic routines.<\/li>\n
                                    • Emphasise everyday indicators of a coupled household: shared rituals, shared parenting, shared celebrations, and financial conduct consistent with a joint domestic life.<\/li>\n
                                    • Use corroboration: where possible, align with other witnesses and external facts.<\/li>\n<\/ul>\n<\/li>\n
                                    • The Respondent\u2019s affidavit strategy:\n
                                        \n
                                      • Narrow the relationship window.<\/li>\n
                                      • Characterise the post-return period as non-romantic co-residence.<\/li>\n
                                      • Introduce a protective-parent justification, framing the living arrangement as child-centred rather than couple-centred.<\/li>\n
                                      • Elevate an administrative note as a shortcut to the Court\u2019s factual finding.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n

                                        A key forensic feature was the mismatch between the Respondent\u2019s dramatic oral description of fear and the absence of those details from the affidavit. Where a party\u2019s affidavit omits a striking claim later advanced orally, that omission can undermine reliability because affidavits are expected to contain material facts supporting the party\u2019s case.<\/p>\n

                                        Strategic Intent Behind Procedural Directions Regarding Affidavits<\/strong><\/h6>\n

                                        When a Court isolates a preliminary issue, such as jurisdictional facts, it effectively directs the parties to concentrate evidence on what matters legally, rather than what is emotionally loud. The strategic reason is efficiency and fairness:<\/p>\n

                                          \n
                                        • Efficiency: determine whether the Court has power before undertaking a full property trial.<\/li>\n
                                        • Fairness: prevent parties incurring disproportionate costs litigating contributions and valuation issues when jurisdiction may fail.<\/li>\n
                                        • Evidentiary discipline: focus affidavits on the statutory test, not moral commentary.<\/li>\n<\/ul>\n

                                          Here, the Court\u2019s approach made the affidavits the primary battleground for reconstructing genuine domestic basis, with oral evidence serving as a stress test for credibility.<\/p>\n

                                          Chapter 5: Court Orders<\/strong><\/h4>\n

                                          Before final resolution of any property settlement, the Court made procedural arrangements consistent with a staged approach:<\/p>\n

                                            \n
                                          • The matter proceeded on a preliminary hearing limited to the jurisdictional question: whether a de facto relationship existed for relevant periods and ended after the critical statutory date.<\/li>\n
                                          • Upon determining jurisdiction, the matter was to be listed before a Registrar for trial directions, enabling the subsequent conduct of the substantive property proceedings.<\/li>\n<\/ul>\n

                                            This staged structure reflects a common family law case management technique: decide the gateway first, then plan the longer trial only if the gateway is satisfied.<\/p>\n

                                            Chapter 6: Hearing Scene: Ultimate Showdown of Evidence and Logic<\/strong><\/h4>\n
                                            Process Reconstruction: Live Restoration<\/strong><\/h6>\n

                                            The hearing unfolded as a focused trial on the single question of relationship status across time. That meant credibility was not a peripheral issue; it was central. The Court was required to decide which narrative was more likely true on the balance of probabilities.<\/p>\n

                                            Cross-examination targeted the Respondent\u2019s claim that he returned to the home for the children\u2019s safety while portraying the Applicant as violent. That account was tested against the Respondent\u2019s own conduct:<\/p>\n

                                              \n
                                            • If the Respondent genuinely believed the Applicant posed a serious risk, why leave the children in her sole care frequently, including during separation and thereafter?<\/li>\n
                                            • If fear was the driver, why was there no contemporaneous legal action aimed at altering care arrangements?<\/li>\n
                                            • If the relationship was purely functional, how did domestic routines, financial support patterns, and family rituals persist in a way consistent with ordinary coupled life?<\/li>\n<\/ul>\n

                                              The Applicant was cross-examined about the Centrelink record and any inconsistencies between that record and her trial evidence. The Respondent sought to treat the administrative note as a confession against interest. The Court, however, treated it as one piece of evidence to be weighed, rather than a legal shortcut.<\/p>\n

                                              Core Evidence Confrontation: The Decisive Moments<\/strong><\/h6>\n

                                              Several evidentiary clashes became determinative:<\/p>\n

                                                \n
                                              1. Credibility under pressure:\n
                                                  \n
                                                • The Respondent\u2019s responsiveness in the witness box, his evasiveness, and embellishment were central to the Court\u2019s assessment of weight.<\/li>\n<\/ul>\n<\/li>\n
                                                • The Centrelink note:\n
                                                    \n
                                                  • The note contained statements inconsistent with agreed chronology, and it did not purport to be a verbatim transcript.<\/li>\n<\/ul>\n<\/li>\n
                                                  • Mundane domestic conduct:\n
                                                      \n
                                                    • The Respondent\u2019s routine calls on the way home asking whether household items were needed was treated as meaningful because it reflected everyday coupledom, not a mere co-residence contract.<\/li>\n<\/ul>\n<\/li>\n
                                                    • Intimate caregiving detail:\n
                                                        \n
                                                      • Evidence of the Applicant performing very intimate grooming tasks for the Respondent was treated as powerful, because it was inconsistent with estrangement as alleged.<\/li>\n<\/ul>\n<\/li>\n
                                                      • Child witness evidence:\n
                                                          \n
                                                        • Evidence from one of the parties\u2019 children about family life during the disputed period provided corroboration beyond the parties\u2019 self-interest.<\/li>\n<\/ul>\n<\/li>\n<\/ol>\n
                                                          Judicial Reasoning: How the Facts Drove the Result<\/strong><\/h6>\n

                                                          The Court\u2019s reasoning method followed the statute-first approach: apply the statutory test under s 4AA by assessing all circumstances, without elevating any single factor into a mandatory element.<\/p>\n

                                                          The Court also applied a composite evaluation approach: not counting \u201cticks\u201d in a checklist, but weighing how the elements interacted to show whether the parties lived together as a couple on a genuine domestic basis.<\/p>\n

                                                          It is rare for me to make a generalised comment about a witness\u2019 credibility but I must say that the Respondent was a most unconvincing witness… I have come to the conclusion that I can place very little, if any, weight on the Respondent\u2019s evidence.<\/p><\/blockquote>\n

                                                          This statement was determinative because once the Court placed minimal weight on the Respondent\u2019s narrative, the case turned on whether the Applicant\u2019s version was plausible, corroborated, and consistent with extraneous facts. The Court accepted the Applicant\u2019s account, not because it was perfect, but because it cohered with the practical pattern of domestic life and credible corroboration.<\/p>\n

                                                          Chapter 7: Final Judgment of the Court<\/strong><\/h4>\n

                                                          The Court made a declaration pursuant to s 90RD of the Family Law Act 1975 (Cth) that:<\/p>\n

                                                            \n
                                                          • A de facto relationship existed between the Applicant and the Respondent.<\/li>\n
                                                          • The periods of the de facto relationship for the purposes of s 90SB(a) were:\n
                                                              \n
                                                            • commencing on a date between 1991 and 1995 until 26 January 2004; and<\/li>\n
                                                            • from November 2005 until 6 March 2016.<\/li>\n<\/ul>\n<\/li>\n
                                                            • The de facto relationship ended on 6 March 2016.<\/li>\n
                                                            • The matter was to be listed before a Registrar for the purpose of making trial directions for the next stage of proceedings.<\/li>\n<\/ul>\n

                                                              The practical effect was that the Court confirmed jurisdiction to hear the anticipated property settlement dispute, because the relationship did not break down on a final basis before 1 March 2009 and satisfied the aggregate duration requirement.<\/p>\n

                                                              Chapter 8: In-depth Analysis of the Judgment: How Law and Evidence Lay the Foundation for Victory<\/strong><\/h4>\n
                                                              Special Analysis<\/strong><\/h6>\n

                                                              This case has jurisprudential value because it demonstrates how Australian family law treats de facto relationships as a question of fact and degree, resisting rigid stereotypes about what \u201ccounts\u201d as a couple.<\/p>\n

                                                              It also demonstrates a legally important and socially realistic principle: a de facto relationship can exist even when one party is simultaneously maintaining another intimate relationship. The statute does not require exclusivity. The Court\u2019s role is to decide whether, in the totality of circumstances, the parties lived together as a couple on a genuine domestic basis.<\/p>\n

                                                              This is especially important in disputes involving hidden second households, where the party denying the relationship attempts to argue that the existence of another partner automatically negates coupledom. The statutory structure prevents that simplistic argument.<\/p>\n

                                                              Judgment Points<\/strong><\/h6>\n
                                                                \n
                                                              1. Statute first, metaphors second:\n
                                                                  \n
                                                                • The Court insisted that descriptive phrases about coupledom cannot replace the statutory test.<\/li>\n<\/ul>\n<\/li>\n
                                                                • Composite picture, not factor-counting:\n
                                                                    \n
                                                                  • The Court evaluated how evidence elements interacted, rather than isolating them.<\/li>\n<\/ul>\n<\/li>\n
                                                                  • Credibility can decide jurisdiction:\n
                                                                      \n
                                                                    • Where the jurisdictional facts depend on lived reality, credibility findings can be decisive and can determine whether the Court has power to proceed.<\/li>\n<\/ul>\n<\/li>\n
                                                                    • Administrative records are relevant but not determinative:\n
                                                                        \n
                                                                      • A Centrelink note may complicate the factual picture but does not dictate the outcome.<\/li>\n<\/ul>\n<\/li>\n
                                                                      • The ordinary can be extraordinary evidence:\n
                                                                          \n
                                                                        • Mundane domestic conduct, repeated over years, can outweigh dramatic oral claims that appear inconsistent with a party\u2019s broader behaviour.<\/li>\n<\/ul>\n<\/li>\n
                                                                        • Corroboration from a child witness can carry significant weight:\n
                                                                            \n
                                                                          • Where a child\u2019s account is compelling and consistent with other facts, it can anchor the Court\u2019s findings.<\/li>\n<\/ul>\n<\/li>\n
                                                                          • Financial patterns matter even without joint bank accounts:\n
                                                                              \n
                                                                            • Separate accounts do not prevent a finding of domestic partnership where other financial interdependence exists.<\/li>\n<\/ul>\n<\/li>\n
                                                                            • Motivation analysis can explain denial:\n
                                                                                \n
                                                                              • The Court was prepared to infer that denial of the relationship\u2019s extent was linked to asset protection motivations, where supported by evidence.<\/li>\n<\/ul>\n<\/li>\n<\/ol>\n
                                                                                Legal Basis<\/strong><\/h6>\n

                                                                                The Court\u2019s analysis operated through the statutory architecture of the Family Law Act 1975 (Cth):<\/p>\n

                                                                                  \n
                                                                                • Section 4AA(1): The core test for de facto relationship status is whether, having regard to all the circumstances, the parties have a relationship as a couple living together on a genuine domestic basis.<\/li>\n
                                                                                • Section 4AA(2): Relevant circumstances include nine factors:\n
                                                                                    \n
                                                                                  1. the duration of the relationship<\/li>\n
                                                                                  2. the nature and extent of common residence<\/li>\n
                                                                                  3. whether a sexual relationship exists<\/li>\n
                                                                                  4. the degree of financial dependence or interdependence, and any arrangements for financial support<\/li>\n
                                                                                  5. the ownership, use and acquisition of property<\/li>\n
                                                                                  6. the degree of mutual commitment to a shared life<\/li>\n
                                                                                  7. whether the relationship is or was registered under a prescribed law<\/li>\n
                                                                                  8. the care and support of children<\/li>\n
                                                                                  9. the reputation and public aspects of the relationship<\/li>\n<\/ol>\n<\/li>\n
                                                                                  10. Section 4AA(3): No particular finding is necessary in relation to any one factor.<\/li>\n
                                                                                  11. Section 4AA(4): The Court may have regard to such matters and attach such weight as seems appropriate in the circumstances.<\/li>\n
                                                                                  12. Section 4AA(5)(b): A de facto relationship can exist even if one party is in another de facto relationship.<\/li>\n<\/ul>\n

                                                                                    Jurisdictional consequences were connected to:
                                                                                    \n– Section 90RD: power to declare whether a de facto relationship existed for the purposes of proceedings.
                                                                                    \n– Section 90SM: property settlement jurisdictional gateway.
                                                                                    \n– Section 90SB(a): aggregate duration requirement relevant to the availability of de facto financial orders.
                                                                                    \n– The statutory cut-off concept: the relationship must not have finally broken down before 1 March 2009 for federal jurisdiction over de facto property matters to be enlivened in the relevant regime.<\/p>\n

                                                                                    Evidence Chain<\/strong><\/h6>\n

                                                                                    Victory Point 1: Reconciliation proved by conduct, not slogans
                                                                                    \n– Evidence: cessation of formal child support deposits and reversion to the prior \u201chousekeeping money\u201d practice; no continued solicitor correspondence to finalise affairs; notification to Centrelink of reconciliation leading to cessation of sole parent payment.
                                                                                    \n– Logic: conduct consistent with resumption of coupled domestic life and inconsistent with a purely functional co-residence.<\/p>\n

                                                                                    Victory Point 2: Domestic routine evidence as a credibility anchor
                                                                                    \n– Evidence: routine calls for groceries, shared rituals like weekly takeaway night, family celebrations.
                                                                                    \n– Logic: repeated mundane acts over years are difficult to fabricate and are strong indicators of genuine domestic basis.<\/p>\n

                                                                                    Victory Point 3: Financial support pattern showing interdependence
                                                                                    \n– Evidence: Respondent paid household outgoings for years and only later sought equal contributions; paid car expenses and gave gifts.
                                                                                    \n– Logic: even with separate accounts, sustained financial support and shared household responsibility supports de facto status.<\/p>\n

                                                                                    Victory Point 4: Child evidence corroborating the household reality
                                                                                    \n– Evidence: child witness described family life from 2005 to 2016 and corroborated domestic tasks and shared routines.
                                                                                    \n– Logic: corroboration reduces the risk that the accepted narrative is merely self-serving.<\/p>\n

                                                                                    Victory Point 5: The Centrelink note neutralised through careful evidentiary treatment
                                                                                    \n– Evidence: note inconsistent with agreed chronology; not a direct quotation; author unavailable; Applicant did not actually receive sole parent payment in the disputed period.
                                                                                    \n– Logic: the note could not bear the weight the Respondent sought to place on it.<\/p>\n

                                                                                    Victory Point 6: The Respondent\u2019s behaviour inconsistent with claimed fear
                                                                                    \n– Evidence: leaving children in the Applicant\u2019s sole care; absence of action to remove children; living arrangement alleged to be imposed despite claimed fear.
                                                                                    \n– Logic: inconsistency undermines the factual foundation of the Respondent\u2019s narrative.<\/p>\n

                                                                                    Victory Point 7: Intimate caregiving detail as persuasive evidence
                                                                                    \n– Evidence: Applicant\u2019s evidence of intimate grooming tasks, corroborated.
                                                                                    \n– Logic: such conduct is strongly inconsistent with a relationship of estrangement maintained over many years.<\/p>\n

                                                                                    Victory Point 8: Double life compatible with de facto relationship under the statute
                                                                                    \n– Evidence: maintained two households apart; children did not mix with the other household; continued cohabitation and couple conduct with the Applicant.
                                                                                    \n– Logic: exclusivity is not required; the legal question is whether the parties lived together as a couple on a genuine domestic basis.<\/p>\n

                                                                                    Judicial Original Quotation<\/strong><\/h6>\n

                                                                                    Each element of a relationship draws its colour and its significance from the other elements… What must be looked at is the composite picture.<\/p><\/blockquote>\n

                                                                                    This quotation was determinative because it supplied the method: the Court was not required to find perfection across every factor. Instead, the Court had to evaluate the entire lived reality, including contradictions, to decide whether, on balance, coupledom on a genuine domestic basis existed.<\/p>\n

                                                                                    The Respondent led a double life. He was the family man when living with the Applicant and his children all the while maintaining a relationship with another partner and keeping the two households apart.<\/p><\/blockquote>\n

                                                                                    This finding was determinative because it directly answered a common defence strategy: the existence of another relationship does not legally erase a de facto relationship, and the Court was prepared to characterise the conduct in a way consistent with the statutory framework.<\/p>\n

                                                                                    Analysis of the Losing Party\u2019s Failure<\/strong><\/h6>\n

                                                                                    The Respondent\u2019s failure was not merely a failure of argument; it was a failure of evidentiary coherence.<\/p>\n

                                                                                      \n
                                                                                    • Overreach in narrative:\n
                                                                                        \n
                                                                                      • The Respondent advanced a dramatic portrayal of fear and violence while simultaneously describing conduct inconsistent with that portrayal.<\/li>\n<\/ul>\n<\/li>\n
                                                                                      • Affidavit and oral evidence mismatch:\n
                                                                                          \n
                                                                                        • Material details emerged orally that were not anchored in affidavit evidence, weakening reliability.<\/li>\n<\/ul>\n<\/li>\n
                                                                                        • Excessive reliance on a single administrative note:\n
                                                                                            \n
                                                                                          • The Respondent treated the Centrelink record as determinative, but the Court treated it as one imperfect summary amid a broader evidentiary landscape.<\/li>\n<\/ul>\n<\/li>\n
                                                                                          • Lack of plausible explanation for ordinary couple conduct:\n
                                                                                              \n
                                                                                            • The Respondent struggled to explain why family rituals, gift-giving, financial support, and daily domestic routines persisted if the parties were truly living separate lives.<\/li>\n<\/ul>\n<\/li>\n
                                                                                            • Credibility collapse:\n
                                                                                                \n
                                                                                              • Once the Court concluded the Respondent was evasive and embellished, the remainder of his case had little secure footing.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
                                                                                                Implications<\/strong><\/h6>\n
                                                                                                  \n
                                                                                                1. Your case is not decided by labels; it is decided by evidence. If you lived as a household, the Court will look at what you did, not what you later call it.<\/li>\n
                                                                                                2. Ordinary routines can become powerful proof. Keep records of consistent patterns: bills paid, household arrangements, family events, and messages that show everyday domestic reality.<\/li>\n
                                                                                                3. A single government record rarely ends the debate. Administrative notes often summarise, sometimes inaccurately, and they are weighed alongside everything else.<\/li>\n
                                                                                                4. If you deny a relationship for asset protection reasons, that motive can become visible in the evidence. The Court can draw inferences from letters, conduct, and timing.<\/li>\n
                                                                                                5. De facto law is built to handle real life, including messy real life. A relationship can be genuine domestically even when one party behaves dishonestly elsewhere. The law\u2019s focus remains the household reality.<\/li>\n<\/ol>\n
                                                                                                  Q&A Session<\/strong><\/h6>\n
                                                                                                    \n
                                                                                                  1. If we kept separate bank accounts, does that mean we were not in a de facto relationship?
                                                                                                    \nNo. Separate accounts can be consistent with a de facto relationship. The Court looks at financial dependence or interdependence and support arrangements overall, including who paid household outgoings and how family expenses were met.<\/li>\n
                                                                                                  2. If one partner had another relationship at the same time, can a de facto relationship still exist?
                                                                                                    \nYes. The statute expressly allows for a de facto relationship to exist even where one person is also in a de facto relationship with someone else. The Court focuses on whether the parties lived together as a couple on a genuine domestic basis.<\/li>\n
                                                                                                  3. How can I protect myself if the other party later denies the relationship?
                                                                                                    \nThe safest approach tends to be contemporaneous documentation: evidence of shared residence, household expenses, family routines, messages reflecting couple life, and witness evidence from people who observed the household functioning. Where possible, avoid relying on a single record and build a coherent evidence chain.<\/li>\n<\/ol>\n
                                                                                                    \n

                                                                                                    Appendix: Reference for Comparable Case Judgments and Practical Guidelines<\/h3>\n

                                                                                                    1. Practical Positioning of This Case<\/strong><\/h4>\n
                                                                                                    Case Subtype<\/strong><\/h6>\n

                                                                                                    De Facto Relationships: Jurisdictional Declaration Dispute for De Facto Property Proceedings<\/p>\n

                                                                                                    Judgment Nature Definition<\/strong><\/h6>\n

                                                                                                    Final Judgment on a preliminary jurisdictional issue (declaration under s 90RD determining the existence and period of a de facto relationship for the purposes of enlivening property settlement jurisdiction)<\/p>\n

                                                                                                    2. Self-examination of Core Statutory Elements<\/strong><\/h4>\n
                                                                                                    Execution Instruction Applied<\/strong><\/h6>\n

                                                                                                    The following legal test standards are presented for reference only. Outcomes tend to be determined by the specific evidence, the credibility findings, and the overall factual matrix.<\/p>\n

                                                                                                    Core Test: Existence of De Facto Relationship \u2013 Section 4AA<\/strong><\/h6>\n

                                                                                                    The statutory question is whether, having regard to all the circumstances, the parties had a relationship as a couple living together on a genuine domestic basis.<\/p>\n

                                                                                                    The Court may consider the following nine circumstances:<\/p>\n

                                                                                                      \n
                                                                                                    1. Duration of the relationship
                                                                                                      \nConsider the overall length of the relationship across time and whether it includes periods of reconciliation. Duration can support an inference of stability and mutual commitment, although a shorter relationship can still qualify depending on other factors.<\/li>\n
                                                                                                    2. Nature and extent of common residence
                                                                                                      \nExamine whether the parties lived under the same roof, how consistently, and with what domestic arrangements. The Court tends to focus on whether the residence operated as a shared home, rather than a mere shared address.<\/li>\n
                                                                                                    3. Whether a sexual relationship exists or existed
                                                                                                      \nThis factor is relevant but not determinative. The Court may accept that health issues, conflict, or separate bedrooms do not necessarily negate coupledom if the broader domestic partnership is established.<\/li>\n
                                                                                                    4. Degree of financial dependence or interdependence, and any arrangements for financial support
                                                                                                      \nLook for patterns such as one party paying the bulk of household expenses, regular provision of housekeeping money, shared responsibility for children\u2019s expenses, or any arrangement that shows the household was financially organised as a unit.<\/li>\n
                                                                                                    5. Ownership, use and acquisition of property
                                                                                                      \nJoint purchase of real property, shared mortgage obligations, shared use of assets, and joint decision-making about major property can support the existence of a genuine domestic partnership.<\/li>\n
                                                                                                    6. Degree of mutual commitment to a shared life
                                                                                                      \nThis factor often turns on evidence of plans, shared routines, sacrifices, caregiving roles, and the overall conduct showing that the parties\u2019 lives were merged to a meaningful extent, even where there are conflicts or periods of dysfunction.<\/li>\n
                                                                                                    7. Whether the relationship is or was registered under a prescribed State or Territory law
                                                                                                      \nRegistration can be persuasive, but the absence of registration does not prevent a finding of a de facto relationship.<\/li>\n
                                                                                                    8. Care and support of children
                                                                                                      \nThe presence of children, shared parenting practices, and joint presentation as a parental unit can strongly support a de facto finding, although it is not automatically decisive.<\/li>\n
                                                                                                    9. Reputation and public aspects of the relationship
                                                                                                      \nConsider how friends, relatives, schools, and the wider community perceived the relationship, noting that different witnesses may have different perspectives depending on proximity and bias.<\/li>\n<\/ol>\n

                                                                                                      Additional statutory directions:<\/p>\n

                                                                                                        \n
                                                                                                      • No particular finding in relation to any one circumstance is necessary.
                                                                                                        \nThe Court tends to avoid turning the list into a checklist where failure on one item defeats the claim.<\/li>\n
                                                                                                      • The Court may attach such weight as seems appropriate to each matter in the circumstances.
                                                                                                        \nThis usually means some evidence will carry disproportionate weight if it is highly probative and credible.<\/li>\n
                                                                                                      • A de facto relationship can exist even if one person is simultaneously in another de facto relationship.
                                                                                                        \nThis is critical in cases involving double lives, overlapping households, or concealed relationships.<\/li>\n<\/ul>\n
                                                                                                        Property Settlement: The Four-Step Process<\/strong><\/h6>\n

                                                                                                        If jurisdiction is established and a property case proceeds, the Court tends to apply a structured approach:<\/p>\n

                                                                                                          \n
                                                                                                        1. Identification and valuation of the net asset pool
                                                                                                          \nIdentify assets, liabilities, and superannuation interests, then determine the net pool. Disputes often arise about valuation evidence and whether certain assets are excluded or quarantined.<\/li>\n
                                                                                                        2. Assessment of contributions
                                                                                                          \nConsider financial contributions, non-financial contributions, and contributions to the welfare of the family including homemaker and parenting duties. Contribution findings tend to be evidence-driven and may be affected by the duration and nature of cohabitation.<\/li>\n
                                                                                                        3. Adjustment for future needs factors
                                                                                                          \nConsider factors such as age, health, earning capacity, care of children, and the practical realities of post-separation life. Adjustments tend to be discretionary and can be relatively modest or significant depending on the matrix.<\/li>\n
                                                                                                        4. Just and equitable evaluation
                                                                                                          \nThe Court conducts a final check: whether the outcome is fair in all the circumstances. This step tends to ensure the result remains grounded in practical justice, not mechanical arithmetic.<\/li>\n<\/ol>\n
                                                                                                          Parenting Matters: Section 60CC Framework<\/strong><\/h6>\n

                                                                                                          If parenting issues arise in related proceedings, the Court\u2019s best interests analysis tends to address:<\/p>\n

                                                                                                          Primary considerations:
                                                                                                          \n– Benefit to the child of having a meaningful relationship with both parents
                                                                                                          \n– Need to protect the child from physical or psychological harm, with greater weight typically given to protection from harm<\/p>\n

                                                                                                          Additional considerations:
                                                                                                          \n– Child\u2019s views, depending on maturity and evidence
                                                                                                          \n– Capacity of each parent to provide for the child\u2019s needs
                                                                                                          \n– Practicalities and expense of spending time, including logistics and stability<\/p>\n

                                                                                                          3. Equitable Remedies and Alternative Claims<\/strong><\/h4>\n

                                                                                                          Even where statutory pathways are narrow or contested, parties in family-related property disputes sometimes explore equitable and common law doctrines, depending on the factual circumstances.<\/p>\n

                                                                                                          Promissory or Proprietary Estoppel<\/strong><\/h6>\n

                                                                                                          Possible pathway where:
                                                                                                          \n– One party made a clear and unequivocal promise or representation about property or financial security.
                                                                                                          \n– The other party relied on the promise to their detriment, such as by contributing labour, money, or foregoing other opportunities.
                                                                                                          \n– It would be unconscionable for the promisor to resile from the promise.<\/p>\n

                                                                                                          Practical note:
                                                                                                          \n– Estoppel claims tend to require strong proof of the promise and reliance. They can be difficult where the evidence is vague or purely oral, but can become more viable where there are contemporaneous communications or third-party corroboration.<\/p>\n

                                                                                                          Unjust Enrichment and Constructive Trust<\/strong><\/h6>\n

                                                                                                          Possible pathway where:
                                                                                                          \n– One party received a benefit at the other\u2019s expense, such as unpaid labour or financial contributions improving an asset.
                                                                                                          \n– Retention of the benefit without compensation tends to be against conscience.
                                                                                                          \n– A remedy could include restitution or recognition of a beneficial interest via constructive trust.<\/p>\n

                                                                                                          Practical note:
                                                                                                          \n– These claims tend to become relevant where ownership is not in joint names but contributions are substantial, or where one party controlled assets in a way that created an inequitable outcome.<\/p>\n

                                                                                                          Procedural Fairness<\/strong><\/h6>\n

                                                                                                          In family law contexts, procedural fairness can still matter in interlocutory disputes and evidentiary rulings:
                                                                                                          \n– Each party tends to be entitled to a proper opportunity to present evidence and respond to adverse material.
                                                                                                          \n– Bias concerns can arise where there is a reasonable apprehension rather than proof of actual bias.<\/p>\n

                                                                                                          4. Access Thresholds and Exceptional Circumstances<\/strong><\/h4>\n
                                                                                                          Regular Thresholds<\/strong><\/h6>\n

                                                                                                          In de facto property matters within the federal family law regime, threshold issues commonly include:<\/p>\n

                                                                                                            \n
                                                                                                          • Duration threshold:\n
                                                                                                              \n
                                                                                                            • A de facto relationship for an aggregate period of at least 2 years tends to be a common gateway.<\/li>\n<\/ul>\n<\/li>\n
                                                                                                            • Jurisdictional cut-off concept for certain regimes:\n
                                                                                                                \n
                                                                                                              • The relationship must not have finally broken down before 1 March 2009 for the relevant federal de facto property jurisdiction in the applicable statutory framework.<\/li>\n<\/ul>\n<\/li>\n
                                                                                                              • Time limit to commence proceedings after breakdown:\n
                                                                                                                  \n
                                                                                                                • De facto property applications tend to be subject to limitation concepts, and parties often need to consider whether leave is required if proceedings are commenced out of time.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
                                                                                                                  Exceptional Channels<\/strong><\/h6>\n

                                                                                                                  Even where typical thresholds are not met, exceptions may arise in family law contexts, including where:
                                                                                                                  \n– There is a child of the relationship, which can affect threshold considerations in certain statutory structures.
                                                                                                                  \n– A party has made substantial contributions and failure to make an order would result in serious injustice, which can sometimes support access to remedies depending on the statutory provision engaged.
                                                                                                                  \n– The factual matrix involves overlapping relationships, and the legal question becomes one of genuine domestic basis rather than exclusivity or social presentation.<\/p>\n

                                                                                                                  Suggestion:
                                                                                                                  \nDo not abandon a potential claim simply because you appear not to meet a standard threshold. Carefully compare your circumstances against statutory exceptions and the evidentiary realities, as the decisive factor tends to be how the Court finds the facts.<\/p>\n

                                                                                                                  5. Guidelines for Judicial and Legal Citation<\/strong><\/h4>\n
                                                                                                                  Citation Angle<\/strong><\/h6>\n

                                                                                                                  It is recommended to cite this case in legal submissions or debates involving:
                                                                                                                  \n– The correct approach to determining de facto relationship status under s 4AA using a composite evaluation of circumstances.
                                                                                                                  \n– The treatment of administrative records, such as government notes, as relevant but not determinative evidence.
                                                                                                                  \n– The compatibility of de facto relationship findings with simultaneous or overlapping intimate relationships pursuant to the statutory framework.<\/p>\n

                                                                                                                  Citation Method<\/strong><\/h6>\n
                                                                                                                    \n
                                                                                                                  • As positive support:\n
                                                                                                                      \n
                                                                                                                    • Where your matter involves long-term co-residence, shared parenting, consistent domestic routines, and financial support patterns, citing this authority can strengthen the argument that the statutory test is met when the composite picture supports coupledom on a genuine domestic basis.<\/li>\n<\/ul>\n<\/li>\n
                                                                                                                    • As a distinguishing reference:\n
                                                                                                                        \n
                                                                                                                      • If the opposing party cites this case, you should emphasise the uniqueness of your facts, such as absence of co-residence, absence of domestic integration, lack of credible corroboration, or materially different financial arrangements, to argue that the composite picture in your matter tends to point the other way.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
                                                                                                                        Anonymisation Rule<\/strong><\/h6>\n

                                                                                                                        In written submissions and public-facing commentary:
                                                                                                                        \n– Do not use real names of parties.
                                                                                                                        \n– Use procedural titles such as Applicant and Respondent, consistent with the judgment header and court practice.<\/p>\n

                                                                                                                        \n
                                                                                                                        Conclusion<\/h6>\n

                                                                                                                        This case demonstrates that in Australian family law, a de facto relationship is proved through the lived reality of the household, assessed as a composite picture under the statute, with credibility and corroboration often deciding the jurisdictional gateway. Golden Sentence: Everyone needs to understand the law and see the world through the lens of law. The in-depth analysis of this authentic judgment is intended to help everyone gradually establish a new legal mindset: True self-protection stems from the early understanding and mastery of legal rules.<\/p>\n

                                                                                                                        Disclaimer<\/h6>\n

                                                                                                                        \u672c\u6587\u57fa\u4e8e\u5bf9\u6fb3\u5927\u5229\u4e9a\u5bb6\u5ead\u6cd5\u9662\u516c\u5f00\u5224\u51b3\uff08Grohl & Acland [2018] FamCA 732\uff09\u7684\u7814\u7a76\u548c\u5206\u6790\uff0c\u65e8\u5728\u4fc3\u8fdb\u6cd5\u5f8b\u7814\u7a76\u548c\u516c\u4f17\u7406\u89e3\u3002\u5bf9\u76f8\u5173\u5224\u51b3\u5185\u5bb9\u7684\u5f15\u7528\u4ec5\u9650\u4e8e\u6cd5\u5f8b\u7814\u7a76\u3001\u8bc4\u8bba\u548c\u4fe1\u606f\u5171\u4eab\u7684\u5408\u7406\u4f7f\u7528\u8303\u56f4\u3002<\/span><\/span><\/p>\n

                                                                                                                        \u672c\u6587\u7684\u5206\u6790\u3001\u7ed3\u6784\u5b89\u6392\u548c\u89c2\u70b9\u8868\u8fbe\u5747\u4e3a\u4f5c\u8005\u539f\u521b\uff0c\u7248\u6743\u5f52\u4f5c\u8005\u53ca\u672c\u5e73\u53f0\u6240\u6709\u3002\u672c\u6587\u4e0d\u6784\u6210\u6cd5\u5f8b\u610f\u89c1\uff0c\u4ea6\u4e0d\u5e94\u88ab\u89c6\u4e3a\u9488\u5bf9\u4efb\u4f55\u5177\u4f53\u60c5\u51b5\u7684\u6cd5\u5f8b\u610f\u89c1\u3002<\/span><\/span><\/p>\n

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                                                                                                                        \u539f\u59cb\u6848\u4ef6\u6863\u6848\uff1a<\/span><\/span><\/h3>\n