Overview
The Inheritance (Provision for Family and Dependants) Act 1975 allows certain individuals to seek financial support from a deceased person's estate when they have not been adequately provided for. For those preparing for the SQE1 FLK2 exam, it is vital to understand the categories of eligible applicants and how courts assess these claims. This article examines the Act's details, recent court rulings, and the factors that influence inheritance disputes.
Eligible Applicants: Categories and Criteria
The Act specifies who can file for financial provision, with each group subject to particular guidelines:
1. Spouses and Civil Partners
Those married to or in a civil partnership with the deceased at the time of death are eligible to apply, enjoying strong legal footing under the Act, as seen in Inheritance (Provision for Family and Dependants) Act 1975 v Ilott [2017] UKSC 17.
2. Former Spouses and Civil Partners
Former spouses or civil partners can apply if they have not remarried or entered into another partnership. Courts consider any financial obligations the deceased had toward them, as in Lilleyman v Lilleyman [2012] EWHC 821 (Ch).
3. Cohabitees
Those who lived with the deceased for at least two years may qualify. Their relationship must resemble a marriage or civil partnership, such as in Churchill v Roach [2002] EWHC 3230 (Ch).
4. Children
This includes biological, adopted, and stepchildren of any age. Adult children often encounter more careful examination, as highlighted in Ilott v The Blue Cross [2017] UKSC 17.
5. Dependants
Anyone financially supported by the deceased might qualify. This broad category can include extended family, friends, or others, exemplified in Rees v Newbery [1998] 1 FLR 1041.
Key Concepts: Financial Dependency and Reasonable Provision
Financial Dependency
Applicants must show they relied on the deceased for substantial support, supported by historical financial evidence.
Reasonable Provision
Courts determine what is fair and adequate for an applicant's needs based on their unique circumstances and dependencies.
Judicial Considerations and Recent Case Law
Courts consider various factors when evaluating claims under the Act:
1. Financial Resources and Needs
Courts consider both current and future needs. In Ilott v The Blue Cross [2017] UKSC 17, the term "maintenance" was clarified as support for everyday expenses.
2. Obligations and Responsibilities of the Deceased
The deceased's societal obligations are weighed, as established in Re Coventry [1980] Ch 461.
3. Size and Nature of the Estate
The estate's value and composition are considered, influencing decisions, as in Nahajec v Fowle [2017] EW Misc 11 (CC).
4. Disabilities of the Applicant
Applicant disabilities can impact financial need assessments, as seen in Re B (Deceased) [2000] Ch 662.
5. Conduct of the Applicant and Others
The conduct of all parties is reviewed, as in Ilott v Mitson [2015] EWCA Civ 797.
6. Moral Duty and Matrimonial Home
Courts often consider moral obligations and any implications related to the matrimonial home.
Complex Scenarios and Practical Applications
Scenario 1: Competing Claims in Blended Families
In cases with a second spouse and children from different marriages, courts balance competing claims, as illustrated in Re Hancock [1998] 2 FLR 346.
Scenario 2: Adult Child with Fluctuating Financial Needs
An adult child facing financial difficulties might claim, as in Espinosa v Bourke [1999] 1 FLR 747, where past support and current needs are examined.
Scenario 3: Cohabitee vs. Estranged Spouse
A cohabitee and estranged spouse both claiming can be complex, as shown in Churchill v Roach [2002] EWHC 3230 (Ch).
Conclusion
The Inheritance (Provision for Family and Dependants) Act 1975 involves legal considerations for SQE1 FLK2 candidates. Key aspects include:
- Defined categories of eligible applicants with specific criteria.
- Multiple factors considered by courts, such as financial needs and estate size.
- Influential case law like Ilott v The Blue Cross [2017] UKSC 17 guides interpretation.
- Complex situations require careful analysis of all relevant factors.
- The principles of financial dependency and reasonable provision are central to the Act.