In Edgar v Public Trustee for the Northern Territory & Anor [2011] NTSC 5 at 46 the court said: There is no onus on the widow as residuary beneficiary under the will to show that she is entitled to be treated as such – or to prove what may be necessary for her proper maintenance and support. Rather the onus is on the plaintiff to show that proper provision is not available for him under the terms of the will.