sband, as the domicile of a wife
follows that of her husband--at the time of the divorce. Domicile means
a person's permanent home, the place at which he resides with no
intention of making his home elsewhere, and, if he leaves it, with the
intention of returning to it.

It is now also clearly recognized as the law of England that the English
courts will not recognize a divorce purporting to be made by a foreign
tribunal with regard to persons domiciled in England. For a considerable
time doubt appears to have clouded the law on this subject. In a famous
case known as _Lolley's_ case, decided in 1812, the judges of England
(the point arose in connexion with a criminal charge) unanimously held
"that no sentence or act of any foreign country or any state could
dissolve an English marriage _a vinculo matrimonii_ for grounds on which
it was not liable to be dissolved _a vinculo matrimonii_ in England."
This case has been frequently understood as deciding that a marriage
celebrated in England cannot be dissolved elsewhere, and on this point
the courts of Scotland differ from the view supposed to be taken by the
English judges. But the matter has been fully explained in one of the
most masterly of Lord Hannen's judgments (_Harvey_ v. _Fairnie_, 5. P.
D. 154), afterwards upheld by the House of Lords in 1882 (8 App. Cas.
43); and it is now clear that while the parties are domiciled in this
country no decree of any foreign court dissolving their marriage will be
recognized here, unless it proceed on the grounds on which a divorce may
be obtained in this country, and even the exception just mentioned
appears to rest rather on reasoning and principle than on the authority
of any decided case. This principle received the highest sanction in the
prosecution of Earl Russell for bigamy before the House of Lords (1901),
in which it was held that, where a divorce had been refused him in
England, an American divorce would not relieve a man from the guilt of
marrying again.

_Summary Proceedings for Separation._--The legislature has sought to
extend the relief afforded by the courts in matrimonial causes by a
procedure fairly to be considered within the reach of all classes. In
1895 an act was passed which re-enacted in an improved form the
provisions of an act of 1878 of similar effect. By the act of 1895 power
was given to a married woman whose husband (1) has been guilty of an
aggravated assault upon her within the Offences against th