ation of the real cause of the disagreement.

In addition to a denial of the charge or charges, the canon law allowed
three grounds of answer: (1) _Compensatio criminis_, a setoff of equal
guilt or recrimination. This principle is no doubt derived from the
Roman law and it had the effect of refusing to one guilty spouse the
remedy of divorce against the other although equally guilty. It was
always accepted in England, although not in other countries, such as
France and Scotland, which also followed the canon or civil law. In
strictness, recrimination applied to a similar offence having been
committed by the party charging that offence. But a decision (1888) of
the English courts shows that a wife who had committed adultery could
not bring a suit against her husband for cruelty (_Otway_ v. _Otway_ 13
P. D. 141). (2) _Condonation._ If the complaining spouse has, in fact,
forgiven the offence complained of, that constitutes a conditional bar
to any proceedings. The main and usual evidence of such forgiveness is
constituted by a renewal of marital intercourse, and it is
difficult-perhaps impossible-to imagine any case in which such
intercourse would not be held to establish condonation. But condonation
may be proved by other acts, or by words, having regard to the
circumstances of each case. Condonation is, however, always presumed to
be conditional on future good behaviour, and misconduct even of a
different kind revives the former offence. (3) _Connivance_ constitutes
a complete answer to any charge. Nor need the husband be the active
agent of the misconduct of the wife. Indifference or neglect imputable
to a corrupt intention are sufficient. It will be seen presently that
modern statute law has gone further in this direction. It is to be added
that the connivance need not be of the very act complained of, but may
be of an act of a similar kind. A learned judge, recalling the classical
anecdote of Maecenas and Galba, said, "A husband is not permitted to say
_non omnibus dormio_." The ecclesiastical courts also considered
themselves bound to refuse relief if there was shown to be _collusion_
between the parties. In its primary and most general sense collusion was
understood to be an agreement between the parties for the purpose of
deceiving the court by false or fictitious evidence; for example, an
agreement to commit, or appear to commit, an act of adultery. Collusion,
however, is not limited to the imposing of other than