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Marital validity & conflict

17 February 2023 / Mark Pawlowski
Issue: 8013 / Categories: Features , Jurisdiction , Divorce
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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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