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of a marriage, which is evidenced by 12 months of separation. Spousal behaviour though, can be a consideration a court may take into account during a property settlement.

Canada

The Supreme Court of Canada held that alienation of affection and the related tort cause of action for "criminal conversation" was not available as a cause of action in the year 1962 in the case of Kungl v. Schiefer, S.C.R. 443. The basis for the claim by the party suing in an Ontario case had been that

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