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e other, or gross and unlawful attack on the honour or personal liberty. (7) Incompatibility of temper and quarrelsome disposition, if rising to the height of endangering life or health. (8) Opprobrious crime for which either spouse has suffered imprisonment, or a knowingly false accusation of such crime by one spouse of the other. (9) If either spouse by unlawful transactions endangers the life, honour, office or trade of the other, or commences an ignominious employment. (10) Change of religion. In addition to these causes, marriages, when there were no children, could be dissolved by mutual consent if there be no reason to suspect levity, precipitation or compulsion; and a judge had also power to dissolve a marriage in cases in which a strongly rooted dislike appeared to him to exist. In all cases of divorce, but sometimes subject to the necessity of obtaining a licence, remarriage was permissible (see Burge, _Commentaries on Colonial and Foreign Law_, vol. i. 649). Before 1876 only a divorce _a vinculo_ could be obtained in some of the German states, especially if the petitioner were a Roman Catholic. The only relief afforded was a "perpetual separation." By the Personal Status Act 1875 perpetual separation orders were abolished and divorce decrees allowed in cases where the petitioners would, under the former law, have been entitled to a perpetual separation order. However, two Drafting Commissions under the act declined to alter the new rule, but under pressure from the Roman Catholic party the Reichstag passed a law introducing a modified separation order, termed "dissolution of the conjugal community" (_Aufhebung der ehelichen Gemeinschaft_). This order can be converted into a dissolution of the marriage at the option of either party. Under the Civil Code of 1900 a petitioner can obtain a divorce or judicial separation on "absolute" or "relative" grounds. In the former case if the facts are established the petitioner is entitled to the relief prayed for; in the latter case, it is left to judicial discretion. The absolute grounds are adultery, bigamy, sodomy, an attempt against the petitioner's life or wilful desertion. The relative grounds are (a) such grave breach of marital duty or dishonourable or immoral conduct as would disturb the marital relation to such an extent that the marriage could not reasonably be expected to continue; (b) insanity, continued for more than three years during the marriage, and of
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