ivic rights.
According to the _Code Civil_, the husband could sue for divorce upon
the adultery of the wife; she, however, could institute such an action
only if the husband kept his concubine at his own home (Article 230).
This provision has been repealed by the divorce law of July 27, 1884,
but the difference continues in force in the French criminal code,--a
characteristic manoeuvre on the part of the French legislator. If the
wife is convicted of adultery, _she is punished with imprisonment for
not less than two months nor more than three years. The husband is
punished only when, according to the spirit of the former Article 230 of
the Code Civil, he keeps a concubine under the domestic roof against the
wish of his wife. If found guilty, he is merely fined not less than 100
and not more than 1,000 francs._ (Arts. 337 and 339 _Code Penal_.) Such
inequality before the law were impossible if but one woman sat in the
French Parliament. A similar law exists in Belgium. The punishment for
adultery by the wife is the same as in France; the husband is liable
only if the act of adultery is committed at the home of the married
couple: he may then suffer imprisonment for not less than one month, or
more than one year. Slightly juster is, accordingly, the law in Belgium
than in France; nevertheless, in the one place as in the other, there
are two different standards of right, one for the husband, another for
the wife. Similar provisions exist, under the influence of French law,
in Spain and Portugal. The civil law of Italy of 1865 enables the wife
to obtain a divorce from her husband only if the husband keeps his
concubine at his own home, or at such other place where the concubine's
presence must be considered in the light of a grave insult to the wife.

In France, Belgium and Switzerland, woman falls, as in Germany, under
the guardianship of her husband, the moment she marries. According to
section 215 of the _Code Civil_, she is not allowed to appear in Court
without the consent of her husband and of two of her nearest male
relations, not even if she conducts a public business. According to
section 213 the husband must protect the wife, and she must yield
obedience to him. There is a saying of Napoleon I. that typifies his
idea concerning the status of woman: "One thing is utterly un-French--a
woman that can do what she pleases."[151] In these countries,
furthermore, woman may not appear as a witness in the execution of
cont