date, and failing this transcription, the decree is void. The
transcription must be made at the place of celebration of the marriage,
or, if the parties are married abroad, at the place where the parties
were last domiciled in France. If the parties, after having married
abroad, return to France, it has been provided, by a circular of the
_Procureur de la Republique_ in 1887, that the transcription may be made
at the place of their actual domicile at the time of action brought, a
rule which has been held to apply to the divorce of aliens in France.
The effect of transcription does not relate back to the date of the
decree.

Opinions may differ as to the relative merits of the English and
French law relating to divorce. But it cannot be denied that the
French law presents a singularly complete and well-considered system,
and one which, obviously with the English system in view, has
endeavoured to graft on it provisions supplementing its omissions, and
modifying certain of its terms in accordance with the light afforded
by experience and the changed feelings of the modern world. The effect
of the laws of 1884 and 1886 in France has been great. The act of 1907
dealing with divorce, coupled with that of the 21st of July of the
same year dealing with marriage, may also be said to mark an epoch in
the laws relating to women. During the five years from 1884 to 1888
the courts granted divorces in 21,064 cases, rejecting applications
for divorce in 1524. In addition, there were 12,242 applications for
judicial separation, of which 10,739 were granted. A distinguished
French writer, the author of a work of singular completeness and
accuracy on the judicial system of Great Britain has compared these
figures with the corresponding result of the English act of 1857. His
conclusion is expressed in these words: "On voit qu'en cinq annees nos
tribunaux out prononce trois fois plus de divorces que la haute cour
d'Angleterre n'en a prononce en trente ans. Je n'insiste pas sur les
conclusions morales a tirer de ce rapprochement" (Comte de
Franqueville, _Le Systeme judiciaire de la Grande-Bretagne_, ii. p.
171). It is, however, practically impossible to compare the number of
divorces in France and in England with exact justice, because, as will
have been seen above, the causes of divorce in France materially
exceed those recognized by English law; and the absence in France of
any offici