Hong Kong,
197
Having regard to the provisions of the En- glish Foreign Marriage Act,1392,it would appear that mar- riages between parties, one of whom, at least, is a British Subject,celebrated outside the United Kingdom, before (e.g.) a British Consul are deemed by English Law to be valid.
Probably the Aerican Law makes similar pro-
visions as regards American subjects. But, with a view to fu-
ture cases, I should be glad to have the matter settled by
勇
authority and I should take no proceedings against the Mi- nister in the meantime.
On the one hand, in Dicey's Conflict of Laws
(published 1896), at p 646 this instance is given: -
"U,a Frenchman marries W an Englishwoman and British Subject, at the Chapel of the French Embassy, without complying with the requirements of English Law as to banns license,&c., The marriage is invalid.
៤
On the other hand at p 636, Dicey, in comment- ing on the English Foreign Marriage Act, 1892, says:-
"It provides modes in which (independently
of the local form) a British Subject may contract a valid marriage in a country outside the United Kingdon.
#
Now I have no copy of the American Law, and I should therefore be glad of some directions for future gui-
dance. Prima facie, the preliminary requirements of our local
law ought to be complied with, and it would rather lie on the Consul and the celebrating Minister to show on what
grounds
:
f