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17 February 2023 / Mark Pawlowski
Issue: 8013 / Categories: Features , Jurisdiction , Divorce
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Marital validity & conflict

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An overseas marriage in the English courts: Mark Pawlowski provides an insight into the complexity of private international law

The story in Taczanowska (Otherwise Roth) v Taczanowski (Lystek cited) [1957] P 301, [1956] 3 All ER 457 begins with the German invasion of Poland in September 1939. Many Poles were deported to German forced labour camps.

A Roman romance 

Krystyna Roth, one such Pole, was deported to Germany, but escaped and journeyed through Europe and, in the winter of 1945, found herself in Italy. As a civilian refugee, she went to Rome to an Italian convent where she resumed her education. Many Poles were active in the war outside Poland. The Polish government in exile established itself in London. Thousands of Polish servicemen escaped from Poland and fought on the Italian front.

On 16 July 1946, Krystyna married Stanislaw Taczanowski in the Parish Church of the Resurrectionists in Rome. They were both Polish nationals, the bridegroom being an officer in the Polish 2nd Corps serving in Italy, in the course of his military duties. The ceremony was performed by a Roman

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NEWS
Talk of a reserved ‘Welsh seat’ on the Supreme Court is misplaced. In NLJ this week, Professor Graham Zellick KC explains that the Constitutional Reform Act treats ‘England and Wales’ as one jurisdiction, with no statutory Welsh slot
The government’s plan to curb jury trials has sparked ‘jury furore’. Writing in NLJ this week, David Locke, partner at Hill Dickinson, says the rationale is ‘grossly inadequate’
A year after the $1.5bn Bybit heist, crypto fraud is booming—but so is recovery. Writing in NLJ this week, Neil Holloway, founder and CEO of M2 Recovery, warns that scams hit at least $14bn in 2025, fuelled by ‘pig butchering’ cons and AI deepfakes
After Woodcock confirmed no general duty to warn, debate turns to the criminal law. Writing in NLJ this week, Charles Davey of The Barrister Group urges revival of misprision or a modern equivalent
Family courts are tightening control of expert evidence. Writing in NLJ this week, Dr Chris Pamplin says there is ‘no automatic right’ to call experts; attendance must be ‘necessary in the interests of justice’ under FPR Pt 25
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