Introduction

There is no rule more firmly established in private international law than that which applies the
maxim locus regit actum to the formalities of a marriage, i.e. that an act is governed by the law
of the place where it is done. Whether any particular ceremony constitutes a formally valid
marriage depends solely on the law of the country where the ceremony takes place. If there is no
ceremony and the courts of the country where the parties are domiciled and resident recognize a
marriage by repute, then so will the English Courts.1
Courts have frequently stressed the absolute nature of both the positive and negative aspects of
this principle. Every marriage must be tried according to the law of the country in which it took
place, and if it is good by that law, then, so far as its formal validity alone is concerned it is
good all the world over, no matter whether the proceedings or ceremony which constituted
marriage according to the law of the place would or would not constitute marriage in the country
of the domicile of one or other of the spouses. The reverse is equally true. If the so-called
marriage is no marriage in the place where it is celebrated, there is no marriage anywhere,
although the ceremony or proceedings if conducted in the place of the parties domicile would be
considered a good marriage.
A. The Rule of Locus Regit Actum
The Rule of Locus Regit Actum simply states that if a marriage is good by the law of the country
where it is affected, it is good all over the world even though the ceremonies would not be
recognised by the country where the parties are domiciled. It is also important to note that the
application of the law of the place of celebration to the formalities of marriage is not disturbed
even though the sole object of the parties to celebrating the marriage abroad is to evade some
irksome requirement of the law of their domicile. Thus, in Simonin v Mallac 2 Two persons,
French by domicile, contracted a marriage in London which, though formally valid according to

1Re Green (1909) 25 TLR 222.

2 (1860) 2 Sw&Tr 67.

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English law, would have been void if tested by French law since the parental consent required by
the Code Napoleon had not been obtained. The wife later petitioned for a decree of nullity.
The Court dismissed the petition, for, since the necessary consent was nothing more than a
formality, its absence could not affect a marriage celebrated in England. Also in Ramos v
Ramos3, the failure to register a marriage as required by the law of the domicile did not affect the
validity of the marriage. If, however, a marriage, valid as to form under the law of the place of
the celebration , but formally void according to the personal law of the parties is later annulled in
the Courts of their domicile, the decree of nullity will be recognised as effective by an English
Court even if the marriage was celebrated in England.
One conclusion to be drawn from the rule that the law of the place of celebration governs the
formal validity of a marriage is that no marriage in England Is formally valid unless it complies
with the requirements of English law as laid down, primarily, in the Marriage Act 1949. In
Gandhi v Patel (2002) 1 FLR 603, the parties in marrying at an Indian restaurant in London in a
Hindu ceremony presided over by a Brahmin Priest acted in knowing and willful disregard of
English Law. The English Court held that In the present case the Hindu Ceremony purported to
be a marriage according to a foreign religion, and it made no attempt to be an English marriage
within the Marriage Acts. Where, however, parties marry in England without acting knowingly
and willfully in breach of the provisions of the Marriage Act 1949, the marriage is not
necessarily denied effect.
This point arose in Chief Adjudication Officer v Bath 4: A couple went through a Sikh marriage
ceremony conducted by a Sikh priest in accordance with Sikh custom and religion at a Sikh
temple in London, which at the material time was not registered. The marriage was not registered
in a register office. The result was that there had not been a valid ceremony in accordance with
the Marriage Act 1949. However, it could not be inferred that the couple had willfully and
knowingly failed to comply with the relevant statutory provisions. The Court relied on the
common law presumption that when there is evidence of a ceremony of marriage having been
gone through, followed by the cohabitation of the parties, everything necessary for the validity of
3 (1911) 27 TLR 515
4 (2000) 1 FLR 8

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the marriage will be presumed in the absence of evidence to the contrary. Having established that
the temple was unaware of the fact of the temples non registered status, EVANS LJ stated:
There is no statutory provision that a marriage otherwise carried out in proper form, by an
authorized celebrant and at a place of worship eligible to be registered under the (1949) Act is
invalid merely on the ground that the building was not registered for whatever reason. Apart
from the presumption, the law as to validity of marriages solemnized or said to have been
solemnized in England is not wholly statutory.
On similar lines, in Pazpena de Vire v Pazpena de Vire (2001) 1 FLR 460, where the parties lived
together as husband and wife for 35 years following proxy marriage ceremony in Uruguay; the
Court held that where there had been a lengthy cohabitation, the presumption of marriage could
be rebutted only by clear evidence that there had been no marriage ceremony or that formalities,
the presumption of marriage could be rebutted only by clear evidence that there had been no
marriage ceremony or that formalities had not been complied with. There was no such evidence
in the instant case, and therefore the presumption was not rebutted.
Retrospectivity of the Rule
It seems almost axiomatic that the question whether the status of husband and wife has been
acquired must be determined once and for all by reference to the law of eth place of celebration
as it stood at the time when the parties went through the ceremony of marriage. According to this
view, the verdict of that law at that time, whether in favor of or adverse to the acquisition of a
married status, will be unaffected by a later change in its provisions. Otherwise the relationship
between the parties will remain insecure.
In Starkowski v A-G5 , however, this conclusion was not fully accepted by the House of Lords,
which held that a marriage void at its time of celebration may be validated by a subsequent and
retroactive change in the law of the place of celebration. H and W Polish by nationality and
domicile were married in Austria on 19 May 1945. The marriage was void by Austrian law since
the ceremony was religious. On 12 June, a daughter, Barbara, was born to them. As from 30
June, Austrian legislation retrospectively validated such religious marriages, subject to their
registration in a public register. In 1949, by which time H and W had both acquired a domicile in
5 (1954) AC 155

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England, their marriage was registered in Austria, so that, by Austrian law, the parties were then
regarded as having been lawfully married since 19 May 1945. In 1950 W and X went through a
ceremony of marriage at Croydon. They had a son, Christopher, born before this marriage.
As indicated earlier, the existence of a marriage may be called into question in many different
situations, and here the house of Lords was concerned with the question of Christophers
legitimacy. If the marriage between H and W was still valid in 1950, W and X were bigamously
married, Barbara was illegitimate and Christopher illegitimate. On the other hand, if it was void,
Barbara was illegitimate, but Christopher had been legitimate by the ceremony between H and W
were determinable according to the state of Austrian law on 19 May or on 30 June, when the
retrospective legislation came into force. It was held that the latter was the appropriate date.
The answers to the two main arguments against this solution were not altogether convincing. The
objection that the status of parties domiciled in England can scarcely be altered by the law o f the
country with which they are no longer connected was ruled on the ground that the Australian
legislation dealt with formalities rather than with status. The further objection, that the parties to
a void marriage will be unable to rely on their unmarried status if the ceremony remains liable to
validation, was met by the reflection that validation will normally not be long delayed.
If the marriage between W and H had preceded the retrospective validation of the marriage
between W and H, then it is suggested that the validation would not be recognised so as to nullify
the second marriage which was wholly valid when entered into. Similarly, if English Court had
granted a decree of nullity in relation to the first marriage, the validity of that decree ought not to
be affected by any later act of registration. If the marriage between W and X came after the
retrospective validation of the earlier marriage, but W was domiciled at the time of her second
marriage in a country which did not recognize the effect of the validation, then the second
marriage ought to be regarded in England as valid.
Matters of Form
The statement that a marriage good by the law of the place of celebration is good all the world
over is accurate only if confined to the question of formal validity. Essential validity is a matter
for the personal law of the parties. This distinction may raise the question whether a particular
rule obtaining in the place of the ceremony affects form or essence. Some matters seem clearly

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to be formal in character such as whether a religious or civil ceremony is required, the time and
place of the ceremony, the persons by whom marriage ceremonies may be conducted, the need
for witnesses, registration of the marriage, prior notification of the ceremony or a requirement of
premarital blood tests. It has been established, for instance, that a rule which permits a marriage
by proxy must be classified as formal since it is concerned with the manner in which the
marriage ceremony may be performed. Thus, if a woman, domiciled and resident in England,
executes a power of attorney appointing X to act as her representative in the celebration of a
marriage between her and Y in a country where marriage by proxy is recognised and the
ceremony is in fact performed, the formal validity of the marriage cannot be impugned. A
marriage ceremony solemnized in such a manner, though not possible in England, is not regarded
as contrary to English public policy. Indeed, the Court of Appeal has upheld the formal validity
of a foreign marriage under customary law where neither spouse was present, bot being in
England at the time of the foreign ceremony. The other important area where the issue of
classification of a particular rule as one of capacity or form has arisen is that of parental consent
to marry. It has been seen that English law classifies this as a question of form in relation to
consent both under English and under foreign law.
Marriages in Foreign consulates and Embassies
It is not wholly clear that the present law is as to celebration of marriages in consulates and
embassies. The question of the formal validity of a marriage celebrated in a foreign consulate
abroad was considered in Radwan v Radwan (No 2)6
In 1951, the husband domiciled in Egypt, married Ikbal in Egypt in polygamous form. In 1952,
he married the petitioner, Mary, a domiciled English woman, in the Egyptian Consulate General
in Paris, in polygamous form, and their matrimonial home was established in Egypt. In 1953, the
husband divorced Ikbal by talak. In 1956, the husband and Mary came to live in England, where
they acquired a domicile. In 1970, the husband obtained a talak divorce from Mary in the
Egyptian Consulate General in London and then Mary petitioned the English courts for divorce.
This matrimonial saga raises a number of separate issues. Firstly, it was held that the talak
divorce in the Egyptian Consulate General could not be recognized in England because the
6 (1973) Fam 35

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diplomatic premises were to be regarded as English and not Egyptian territory.7There was
however, the logically anterior question of the validity of the marriage in the Egyptian Consulate
General in Paris and this was considered in the later proceedings in the case. Two questions had
to be examined-whether the parties had capacity and whether the marriage was formally valid.
CUMMING-BRUCE J decided that, although Mary was incapable by English law of entering a
polygamous marriage, she was capable by Egyptian law, the law of the intended matrimonial
home. As to the formal validity, the Court held that the Egyptian Consulate General in Paris was
to be regarded as French and not Egyptian territory. French law, as the law of the place of the
celebration, had to be applied to questions of formal validity. The Court presumed the marriage
to be formally valid in the absence of decisive evidence of French law to rebut this presumption.
While this case provides clear authority for the view that a marriage abroad in a foreign embassy
or consulate must comply with the formalities of the receiving state, there remains the problem
of marriages in England in foreign diplomatic premises. There is some authority for the view that
such marriages are formally valid if both parties are nationals and perhaps domiciliary of the
foreign states.8 The opinion has been expressed at the diplomatic rather than judicial level that
marriages in a foreign embassy between nationals of the sending state will be regarded as valid,
but that, apart from diplomatic convention, consular marriages must comply with the formalities
of English law. The rejection of the idea of extra territoriality is certainly consistent with the
reasoning in Radwan v Radwan (No 2) 9where the decision that the marriage in Paris must
comply with French law was supported by reference to the earlier conclusion that the divorce in
London must be regarded as English and not an Egyptian divorce.
The Doctrine of Renvoi and the Rule of Locus Regit Actum
It has been assumed up to this point that formalities are to be governed by the internal law of the
place of celebration; but there is some authority that the doctrine of renvoi applies in this area
7 Radwan v Radwan (1973) Fam 24; Polonsky (1973) 22 ICLQ 343
8 Bailet v Bailet(1901) 17 TLR 317;Portreis v Tondear (1790) 1 HagCon 136; Ruding v Smith (1821) 2
HagCon 371
9 (1973) Fam 35

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with the result that a marriage will be formally valid if it complies with the formal requirements
of whatever law is selected by the choice of law rules of the place of celebration. In
Taczanowska v Taczanowska10: Two Polish nationals, domiciled on Poland, were married in Italy
in 1946 in a military camp, the husband being a member of the allied occupation forces in Italy.
The ceremony did not comply with the formal requirements of the Italian law, but the Court
considered the rule of Italian law that the marriage would be regarded as valid by the Italian
Courts of it complied with the formal requirements of Polish law, the law of the parties common
nationality.
In fact the marriage was not formally valid under Polish law, though it was held valid in England
as an exception to the general rule of reference to the law of the place of celebration.
Nevertheless, it seems to have been assumed that the English Courts would have regarded the
marriage as formally valid had Polish law so regarded it, applying the renvoi doctrine of
transmission from Italian law.
Another issue is the position if a marriage satisfying the formal requirements of the domestic law
of the place of celebration, but not those of the country referred to by its choice of law rules.
Although there is no direct authority on this issue, it has been suggested that in the interests of
upholding the validity of marriage, the English Courts should regard the marriage as valid if it
complies either with the domestic law of the place of celebration or with the system of law which
would be applied by that countrys choice of law rules. The Irish Law Commission whilst
supporting generally the application of the doctrine of renvoi in the case of formal validity of
marriage in the interests of upholding the validity of marriages and promoting uniformity of
status, rejected such an alternative reference rule, despite its convenience on the ground that it
would lead to the marriage being regarded in England as formally valid, though not so regarded
in the place of celebration.

(B) Exceptions to the general rule

10 (1957) P 301

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There are two statutory exceptions and once common law exception to the rule that the law of
the place of celebration governs formalities:
(i)

The Two Statutory Exceptions

a. Consular Marriages

What is generally called a consular marriage is the first exception. The Foreign marriage Act
1892, as amended by the Foreign Marriage Act 1947 and the Foreign Marriage Amendment Act
1988 provides that any marriage between parties one of whom atleast is a United Kingdom
National11 solemnized before a marriage officer in a foreign country in the manner prescribed
by the Act, shall be valid as if it had been solemnized in the United Kingdom with the due
observance of all forms required by law. The persons who may be appointed marriage officers
include British Ambassadors, High Commissioners and consular officers, but they must hold a
marriage warrant from the State. 12
The 1892 Act lays down various requirements as to such matters as parental consent, the giving
of notice of the marriage and the registration of marriage. Section 8 is the most important section
and it provides that every marriage must be solemnized at the official house of the Marriage
Officer, with open doors, in the presence of two or more witnesses and according to such form
and ceremony as the parties see fit to adopt. Where a statement that the parties see no
impediment to their marriage would not be included otherwise in the ceremony adopted, they
must each declare: I solemnly declare that I know not of any lawful impediment why I AB may
not be joined in matrimony to CD.
Similarly, if not otherwise stated in the ceremony adopted, each party must make the following
declaration: I call upon these persons present here to witness that I AB take thee CD to be my
lawfully wedded wife (or husband).

11 Defined in s 1(2) of the 1892 Act

12 Section 11 of the 1892 Act.

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It has been held that Section 8 is the crucial section of the Act and is mandatory in nature whilst
other sections namely 2, 3, 4, 7 and 9 are administrative or procedural and are only discretionary
in nature. 13Failure to comply with these latter sections does not render the marriage invalid.
A marriage contracted under these statutory provisions is necessarily formally valid in England,
even though it may be void in the law of the country where it took place. 14However, any real
danger that the marriage solemnized under the Act may be regarded as void under the law of the
place of celebration has been virtually eliminated by the Foreign Marriage Order 1970. This
provides that a Marriage Officer must not solemnize a foreign marriage unless he is satisfied:
1) that atleast one of the parties is a UK National
2) that the authorities of the country will not object to the solemnization of the marriage
3) that insufficient facilities exist for the marriage of the parties under the law of that country
4) the parties will be regarded as validly married by the law of the country in which each party is
domiciled.
Furthermore, the 1892 Act provides that a marriage officer is not required to solemnize a
marriage if to do so would be inconsistent with international law or the comity of nations. 15 It
is far from clear what this means and whether it is of any force in the light of the conditions just
listed above. However, nothing in the 1892 Act is to conform, impair or affect the validity of
marriage celebrated abroad other that the Act provides. This means that a marriage valid as to
some other exception is still to be regarded as valid.
(a) Marriages of Members of British force serving abroad
Section 22 of the Foreign Marriage Act 1892 as substituted by the Acts of 1947 and 1988
provides that a marriage solemnized in any foreign territory by a chaplain serving with any part
of the naval, military or air forces of His Majesty serving in that territory or by a person
13 Collett v Collett (1968) P 482
14 Hay v NorthCote (1900) 2 Ch 262.
15 Foreign Marriage Act 1892, section 19.

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authorized by the Commanding forces serving in that territory shall, subject as hereinafter
provided, be as valid in law as of the marriage had been solemnized in the United Kingdom with
a due observance of all forms required by law.
A marriage celebrated under the Cat is valid whether the Armed Forces are on active service or
in the occupation of the foreign territory after the successful conclusion of hostilities ore merely
stationed there. There is no necessity for one of the parties to be a British subject.16
(ii)

The Common Law exception

There are certain exceptional circumstances in which a marriage may be recognised even though
it has not been solemnized according to the law of the place of celebration, provided it satisfies
the form required by the Common law of England. Before discussing the nature of these
exceptional circumstances, the meaning of a common law marriage must be clarified, since it
emerged at a time when the Canon law governed the matrimonial affairs of Christians throughout
Western Europe.
The only essential to the formal validity of a marriage required by the Original Common Law
was that the parties should take each other as husband and wife. In 1843, however, the further
common law conditions was added that an episcopally ordained Priest or Deacon, whether of the
English or the Roman Catholic Church should perform the ceremony. This was decided by the
House of Lords in R v Millis 17 where it was held that though in a rather unsatisfactory manner
that a marriage celebrated in Ireland by a Presbyterian minister according to the rites of the
Presbyterian Church was invalid. There are several situations in which a marriage may be
celebrated outside England and these shall have to be considered to determine whether the
marriage is formally valid if it satisfies the requirement of the common law.
1- Where the Common Law is in force in the foreign country
The first situation is where the common law of England continues to govern the parties even
in the foreign country where they take each other as husband and wife. This can be illustrated
16 Taczanowska v Taczanowska (1957) p 301
17 (1844) 10 Cl&Fin 534

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by the early days of Colonialism It was consistently recognised as a matter of Constitutional

Law that the British settlers in such countries as Australia took English Common Law with
them, but only so much of it as was suitable to local conditions. 18 Tested by this principle it
seems clear that the rule of the common law requiring the intervention of an episcopally
ordained Priest could scarcely be extended to a marriage contracted in a colony during the
early days of the colonization when there was no Church establishment and there was no
division into Parishes. The weight of judicial opinion was always in favor of treating the rule
in R v Millis as being confined to marriages in England and Ireland; and in Catterrall v
Catterrall19 Dr. Lushington held that a Marriage which had been celebrated in Sydney in 1835
by a Presbyterian Minister was valid at Common Law.
The proposition may be illustrated by two cases:
Wolfenden v Wolfenden20: A Canadian, whose domicile of choice appears to have been
English, went through a ceremony of marriage with a Canadian woman in China. The
ceremony was performed not by an especially ordained Priest but by the local Minister of the
Church of Scotland Mission. A Chinese Order in Council was in force which after reciting
that a Treaty had given His Majesty the jurisdiction in the Republic of China proceeded to
establish a system of Judicature there and provided that the Civil Jurisdiction of every Court
acting under the Order should as far as circumstances permit be exercise on the principle of
and in conformity with English law for the time being in force.
LORD MERRIMAN P held that the marriage was valid at common law. The parties had
freely consented to it and the circumstances precluded the presence of an episcopally
ordained Priest.

18 Blackstone, Commentaries on the Laws of England, I, 108

19 (1847) 1 Rob Eccl 580
20 (1946) P 61.

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A similar decision was reached in Penhas v Tan Soo Eng 21. Certain Charters of Justice
introduced in the first half of nineteenth century introduced English law into Singapore, but
provided that it should be administered in such a manner as the religions, manners and
customs of the inhabitants would admit. Therefore, a marriage ceremony in 1937 between a
Jew and a Chinese woman, both British Subjects domiciled in Singapore, at which the man
observed the Jewish custom but the woman followed the Chinese rites was held to be valid at
common law. The parties included the composite ceremony to record that they took each
other as man and wife. The Rule in R v Millis was inapplicable.
2- Inseparable Difficulty
The second exceptional situation is where the parties, though not subject to the common law
in the foreign place of celebration have, nevertheless, without regard to the local formalities,
taken each other as husband and wife at a ceremony performed, usually by an episcopally
ordained Priest. In such a case, the marriage will be regarded as valid if compliance with the
local formalities had been prevented by some insuperable difficulty.22
What is meant by insuperable difficulty has been expressed in various ways. LORD
STOWELL considered that legal or religious difficulties might justify a relaxation of the
Principle of locus regit actum in Ruding v Smith 23. LORD ELDON was clear that the parties
might invoke the common law of they could not avail themselves of the law of the place of
celebration or of there was no local law. He accordingly held that a marriage between
Protestants at Rome solemnized by a Protestant Priest was valid since no Catholic Priest
would be allowed to perform the ceremony. The parties have to have found it impossible or
virtually impossible to comply with the local law. It is not enough that they found it
inconvenient, embarrassing or distasteful so to comply, as in Kent v Burgess 24 where a
21 (1953) AC 304
22 Kent v Burges(1840) 11 Sim 361
23 (1821) 2 HagCon 371
24 (1840) 11 Sim 361

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marriage in Belgium was held void for non compliance with Belgian residence requirements
there being no insuperable difficulties in the parties waiting the prescribed six month period.
3- Marriages of Military Forces in Belligerent Occupation
Circumstances can be envisaged where, although compliance with the local law is not
impossible, it might be thought unreasonable. Such a problem in Europe at the end and in the
aftermath of Second World War, when many people married without recourse to the civilian,
often Nazi authorities. The problem is illustrated in the leading decision of Taczanowska v
Taczanowski. The Court of Appeal felt that, since the parties were presumed not to have
submitted themselves to the Italian law of the place of celebration, that law did not have to be
applied. It was considered that there will often be no submission by a member of the military
forces in occupation of the country, and such was held to be the case here. As Italian law was
not applicable and the law of the parties domicile was considered irrelevant, English
common law was applied and the validity of the marriage upheld.
Such a general principle of submission underlies the decision in Lazarewickz v
Lazarewickz25 where a Polish Corporal, serving with the Polish Army in Italy was married in
1946 in Barletta in Italy to an Italian national. The ceremony, performed at a Polish Refugee
Camp by a Catholic Priest did not comply with Italian law. The Judge held that there was
evidence of the parties intention to submit to Italian law; the husband had married not as a
member or within the lines of the Army of occupation, but as an ordinary sojourner in a
subject to the laws of the foreign state. Reliance on the common law was therefore precluded
and the marriage was held to be void.
This decision adds further support to a general theory that the basis of the rule of locus regit
actum is the presumed intention of the parties to submit themselves to the law of the place of
the celebrations. It is suggested, however, that this theory of submission, if it purports to
represent a general principle applicable to marriages other than those in an occupied country
or in a country where it is insuperably difficult to comply with the local law, is neither
supported from previous authority nor is free from objections.

25 (1962) P 171

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The conclusion to be drawn is that the principle of submission canvassed in the Taczanowska
case and other decisions is very limited. It is relevant only to marriage contracted by a
member of a conquering force in the conquered country. This is the one type of case in which
it is not unreasonable to offer the parties an alternative to the law of the place of celebration
for the incongruity of compelling a conqueror to submit to the conquered is obvious.
4- Marriages on the High Seas
There is little authority as to what constitutes a valid marriage solemnized in a merchant ship
while on the high Seas. The general principle is that the law of the flag governs transactions
onboard a vessel, for, as BYLES J once said, a British Ship is regarded as a floating island on
which British law prevails.26 Thus the common law is in force on a ship as in the analogous
case of a colony, except where the common law has been modified by a Statute. To make the
analogy complete, it must also be conceded that only so much of the law is imported into the
ship as is suitable into the local conditions. That raises the question whether it suffices that
the parties have freely taken each other as husband and wife or whether in accordance with R
v Millis, it is necessary that the ceremony should have been performed by an episcopally
ordained Priest. It has sometimes been suggested that the absence of a priest is fatal to the
validity of a marriage at sea, unless it is a marriage of necessity. It is taken from the Du
Moulin v Druitt27 in which: A woman stowaway was discovered on a troopship during a
voyage to Australia. The commanding officer ordered that she and one of the soldiers on
board should immediately be married and the marriage was celebrated in his presence. In
fact, as soon as the ship arrived in Sydney, the woman left the husband and went to live with
the officer who acted as clerk in the marriage ceremony. Later, they married in the lifetime of
the soldier, and the issue arose as to the validity of the ship board marriage. The Court held
that the rule in R v Millis was applied and that the ship board marriage was void on the
ground that the marriage was not of necessity since the vessel would touch upon places
where a Priest would be available.
Conclusion
26 R v Anderson (1868) LR 1 CCR 161 at 168
27 (1860) 13 ICLR 212

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The Principle of Locus Regit Actum has been held to be one of the most important doctrines
of the subject matter of Laws. The Rule which has been an extension of the significance of
the Common Law Marriages since the time of colonization, simply states that a marriage is
valid if it is held according to the ceremonies of the domicile. However, time has proved that
this rule is also not free from exceptions. The Statutory Exceptions and Common Law
Exceptions are the most recognised.