When is a marriage not a marriage, asks Jonathan Herring
It is increasingly common to marry overseas. In 2010 around 74,000 couples did. Rarely does that cause legal problems, but it can do as Galloway v Goldstein [2012] EWHC 60 (Fam) demonstrates.
Married on two continents
The husband was English and his wife American. Perhaps concerned about the rates of marriage breakdown, or perhaps just for the fun of it, they decided to get married twice: once in Connecticut, US, in April 1999 and then again one month later in England. There would have been no problem if the English ceremony had been in the nature of a blessing. But, it was not, it was a full marriage, registered at the General Register Office of England and Wales. By 2004, the marriage had broken down and was dissolved by the Superior Court of Connecticut. The US proceedings made no mention of the English ceremony, but made appropriate financial orders.
Some years later, the husband became concerned about the status of the English ceremony. In particular, he was concerned that in the event of his
