Application for leave — Property (Relationships) Act 1976, s 24 — West v Perry [2002] NZFLR 796 — Ritchie v Ritchie [1992] NZFLR 226. Application for leave refused due to insufficient evidence given to support explanation of delay and absence of prima facie merit to application. The issue was whether the applicant could provide a satisfactory explanation for the delay in applying for leave. While there is no onus on the applicant there is an obligation to advance evidence to support an application (Ritchie and Perry). Time limit for making an application after an order has been made declaring a marriage void is 12 months after the date of the order or for a de facto relationship no longer than three years after the relationship has ended (PA, s 24). Though delay is not fatal to the application if a satisfactory explanation is given. Judgment Date: 14 April 2017.