—it was held "that the English Courts will recognize as valid the decision of a competent foreign Christian tribunal dissolving the marriage between a domiciled native in the country where such tribunal has jurisdiction, and an Englishwoman, when the decree of divorce is not impeached by any species of collusion or fraud. And this, although the marriage may have been …

Much confusion has arisen from the distinction between the two not having been observed; and the rules that have been laid down for determining the validity of a marriage, where the ceremony was alone in question, have sometimes been used in determining whether it was lawful for the parties to intermarry, as if the subject was the same in both cases, instead of there …

It cannot be doubted, also, that the courts of England decline to treat a foreign decree of divorce as having obligatory extraterritorial force when both parties to the marriage were not subject to the jurisdiction of the court which rendered the decree.

—the courts of England, in cases where the jurisdiction was dependent upon domicil, have enforced the presumption and treated the wife as being within the jurisdiction where the husband was legally domicled.

Attitude of English law to non-judicial divorce There can be no doubt that the law of the domicile is prima facie the proper law for determining the efficacy of a purported divorce to bring about a change of status by dissolving a marriage: Harvey

—"one of the numerous wives of a Mohammedan was to come to this country, and marry in this country, she could not be indicted for bigamy, because our laws do not recognise a marriage solemnized in that country, a union falsely called marriage, as a marriage to be recognised in our Christian country."

Lord Selborne said (52 LJP, at p. 35; 8 App. Cas., at p. 50): "Let it be granted (and I think it is well settled) that the general rule, internationally recognised, as to the constitution of marriage is, that when there is no personal incapacity attaching upon either party, or upon the particular party who is to be regarded, by the law to which he is personally subject, that is the law of …

Hardy said (p. 238) the wife "by her conduct manifested her election to treat herself as not having a separate domicile, but as following her husband's domicile in New York. This being so, it is now settled by (88) authority which binds us that the Court of the country in which the parties were domiciled-that is to say, New York—was the Court having jurisdiction to decree a …

It may mean the solemnity by which two persons are joined together in wedlock, or it may mean their status when they have been so joined

—church of England. They are nized by the English courts:(1) if it was pro-marriage celebrated in England) will be recogof many denominations, principally presbyte-nounced for grounds on which the marriage was rians, independents, methodists and baptists; liable to be dissolved in England (Solley's Case, but as to church government, the baptists are independents …