MARRIAGE PUZZLES.

Gisborne Times, Volume XXV, Issue 2020, 4 March 1907, Page 1

MARRIAGE PUZZLES.

So many distressing cases have arisen in which English girls have married foreigners and then found that their marriages are not strictly legal in theif adopted countries, that an official warning was issued recently on the subject. The marriage laws of England and Europe present some strange puzzles. It sometimes happens that a person is regarded as legally married in one country, and single in another. This arises generally from lays requiring t)ip cqiisent of parents when the parties are under certain ages. In France, for instance a man under 25 and a woman under 21 cannot marry without the consent of their parents. In the case of disagreement, the father’s consent prevails over the mother’s, and if both parents arc deal] tjiq yqung man must obtain the consent of his nearest relatives. In one famous case ..a young Frenchman married without obtaining the consent of his two grandmothers, who were both widows. At length one grandmother gave her consent, and after a protracted law case it was decided, that this was sufficient to legalise the union. Distressing cases arise out of this complex system. French law regards consent” as essential, but in English law it is only a formality, so that two French people can go to England and marry without the consent of their parents. But they would bo regarded as unmarried in France, and their children, legitimate in England,would he. illegitimate in their own country. A Frenchman can, if he is blackguard enough, go to England and marry an English girl without observing the proper form, and get the marriage annulled in France at his pleasure. The validity of alien marriages is governed in essentials by the law in force at the dbmicile of the parties, and in formalities by the law of the country in which the marriage is celebrated. The Portuguese law forbids the mqrriage of first cousins. Therefore, If two Portuguese first cousins married in England, according to the strict letter of the English law tlie marriage would he held invalid by an English Court as well as by all foreign Courts, as one of the essentials of the law of the domicile had been contravened. If they had previously become domiciled in England, i.e., English subjects, the marriage would be legal. Similarly, if a Dane married his deceased wife’s sister in England, and under its laws, an English Court would hold it valid, although the English law forbade it. If, however, the parties were domiciled in England, it would be invalid. Russian law is curious in that no matter what age a man is, the consent of one parent is essential. A man cannot marry there after 80, or after he has been married three times.