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14. It was farther held in Perianayakam v. Pottukanni (I. L. R., 14 Mad., 382), that a pariah who was converted to Christianity was not entitled to a decree for divorce on the ground of adultery committed by his wife before his conversion, and that the Court had no jurisdiction to entertain his petition under Act IV of 1869. The ground of decision was that the Act applied only to Christian marriages. Having regard to the decision in Brinkley v. Attorney-General (L. R., 15 P. D., 76), the expression 'Christian marriages ' must be taken to convey the idea, not that the parties must profess Christianity, but that the marriage must be of a kind recognized in Christian countries, viz., that the marriage must be that of one man and one woman for life to the exclusion of all others. That was a case in which the petitioner was a British subject with an Irish domicile of origin. When he temporarily resided in Japan, he married a Japanese woman in Japan according to the forms required by the law of that country. It was proved in that case that, according to the law of Japan, it was a valid marriage, and by that law the petitioner was also precluded from marrying any other woman during the subsistence of that marriage. The learned Judge recognized the Japanese marriage as valid under the Legitimacy Declaration Act (21 and 22 Vie., cap. 93) and explained the ground of decision in these terms : " This case is clear from the difficulties which arose in the Mormon case and in the South African case, because in both these cases there was an attempt to establish as a valid marriage a marriage with another person than the first spouse. The principle laid down by these cases is that a marriage which is not that of one man and one woman to the exclusion of all others, though it may pass by the name of marriage, is not the status which the English law contemplates when dealing with the subject of marriage." But in this case it has been proved by the law of Japan, " marriage does involve this idea, viz., that one man unites himself to one woman to the exclusion of all others. Therefore, though throughout the judgments which have been given on the subject, the phrase 'Christian marriage,' or marriage in Christendom or some equivalent expression has been used, that has been used only for the sake of convenience, and the idea which has to be expressed was this--that the only marriage recognized in Christian countries or in Christendom is the marriage of the exclusive kind." This decision is clear authority on the one hand for construing the expression ' Christian marriage' used in Perianayakam v. Poitukanni (I. L. E., 14 Mad., 382) in the sense indicated above, and on the other, for the opinion that the Court for Divorce and Matrimonial Causes in England gives relief in such causes subject to two conditions, viz., [241] that the marriage is valid according to the lex loci, and that the idea of the union of one man and one woman to the exclusion of others is present in it, as in marriages between persons professing the Christian religion and thereby implies the status contemplated by the English law whilst dealing with the subject of marriage. Turning to the case before us, I do not think that the Act is applicable to it. In a Hindu marriage the idea of the exclusive union of one man and one woman for life is not present as in a marriage recognized by the Court for Divorce and Matrimonial Causes in England, and section 7 of Act-IV of 1869 directs that we should give relief under Act IV of 1869 on principles and rules which may be conformable to the principles and rules by which that Court gives relief. The preamble of the Act states that it is expedient to amend the law relating to the divorce of persons professing the Christian religion, and the second paragraph of Section 2 declares that nothing herein contained shall authorize any Court to grant any relief under this Act, except in cases where the petitioner professes the Christian religion. These provisions render it probable that the marriage which the Act purported to deal with was marriage founded on the Christian principle. Again in Section 2, Clause 8, marriage with another woman is stated to mean marriage of any person being married during the life of the former wife, and it is provided by section 18 that a marriage may be declared null and void on the ground, inter alia, that the former wife was living at the time of the marriage and that the marriage with the former wife was then in force. Take for instance the case of a Hindu with two or more wives becoming Christians, and suing under the Act to have it declared that all his marriages but one are null and void. Are we to pass a decision in his favour ? If so, which of his several marriages is to be declared null, and if we are to declare all marriages except the first null and void, are we not acting in contravention of the rule that conversion to Christianity does not dissolve prior marriages valid by the lex loci ? If the legislature had intended to bring Hindu marriages within the scope of the Act, they would probably have inserted express provisions relating to questions which arise from their polygamous character. It is true that the plaintiff has married only one wife, though whilst a Hindu he was at liberty to have married several wives at the same time, and it may be suggested that the particular Hindu marriage now before us may be treated as monogamous in fact, entitling the plaintiff to the relief claimed. There are two objections to the adoption of this suggestion. The first is that what we have to consider is, the status consequent on a marriage as regulated by the lex loci or the legal conception of the marriage, and not whether the plaintiff in a given case has in fact married one wife or several wives. Another objection is that the suggestion is not the natural result of interpretation which can be put on the Act, though it may form an appropriate subject of legislation. I do not see my way to hold that Hindu marriages are marriages contemplated by the Act.