For instance, in cases of short single-income marriages, without going so far as to set out the applicable considerations, Debbie Ong JC cited Zhou Lijie v Wang Chengxiang  SGHC 316 as a starting point for childless, single-income marriages of moderate length. While the “structured approach” would continue to apply to dual-income marriages going forward, sensible adjustments within the same, taking the factual nuances of each case into consideration, would help achieve a fair result. For instance, a higher weightage might be accorded to direct financial contributions in short dual-income marriages, as in the case of ATE v ATD  SCGA 2, while Debbie Ong JC observed that equality of division might prevail in cases involving long marriages with children, whether they are single- or dual- income. In any regard, the broad-brush approach remains fundamental in guiding the court’s exercise of discretion, and preventing matrimonial disputes from descending into protracted, coldly calculative litigation.
In considering these recent developments, one might recall the rationale for the introduction of the “structured approach” in ANJ v ANK. In replacing the “uplift methodology”, previously used to recognise the indirect contributions of one spouse, the “structured approach” represented a shift towards, firstly, system and consistency, and secondly, the affirmation of the philosophy of marriage as an equal partnership of different, but equally valuable, efforts.
TNL v TNK and UBM v UBN thus provide a timely and important qualification as to the application of the structured approach, ensuring a just and equitable outcome is not sacrificed at the altar of consistency. While certain areas of the law remain to be addressed – most visibly, the applicable considerations in cases of short single-income marriages – neither does the emerging taxonomy of marriages necessarily herald a return to the wilderness of the uplift methodology. The precedent cases cited in UBM v UBN demonstrate how the “structured approach”, when used together with appropriate internal adjustments and the fundamental broad-brush approach, may achieve outcomes which are both equitable and consistent. What is certain, however, is that in re-evaluating the road to a just and equitable outcome, the developments in this area of the law will continue to be watched with interest.