Higgins v Higgins - [1959] NZLR 326

National expenditure adjustment — Annuity payable to divorced wife under husband's deed of covenant entered into on making of decree absolute — Husband's performance of obligations thereunder secured by husband and second wife giving security over their jointly-owned property — Death of husband — Second wife's application for modification of maintenance payments — Second wife able to comply with terms of deed of covenant without "causing undue hardship" — Application refused — "Undue hardship" — National Expenditure Adjustment Act 1932, s. 42.