Jayewardene v. Jayewardene Nee Pereira – sllr 1980 volume 2 page 114
In the case between the wife (petitioner) and the husband (respondent), concerning a matrimonial property dispute, the court addressed whether a sum of Rs. 10,000, including Rs. 9,000 allegedly used by the husband, could be regarded as identifiable property under Section 23 of the Married Women’s Property Ordinance. It was held that the disputed funds constituted a mere chose in action, not an “identifiable or definite property,” and therefore were not amenable to relief under the summary procedure of the Ordinance. The decision reaffirmed that for relief under Section 23, the property must be a specific, traceable asset and not a general debt obligation. Reliance was placed on statutory interpretation and authorities such as Tunstall v. Tunstall, Rimmer v. Rimmer, and Crystall v. Crystall

