innocent party, and she has the right to claim maintenance from her husband. But the husband, on the other hand, is always entrusted with the guardianship of his children, even if the wife is granted the right to their custody.

(2) Divorce:

The rights and duties of husband and wife with regard to divorce proceedings and their consequences are in general equal in Australia, Ceylon, Denmark, France, Germany, Holland, Norway, Sweden, Scotland, Switzerland, and Yugoslavia.

In Belgium and Spain, the law originally drawn up by Napoleon provides — with respect to granting the right of divorce to either man or woman — that the husband may seek divorce on account of his wife's commission of the crime of adultery. As for the wife, she may seek divorce for her husband's commission of immorality only if it took place in the conjugal home.

In Britain and Northern Ireland, the wife has the right to seek divorce if her spouse is charged with debauchery.

In the Union of South Africa, the divorced woman is given no right of guardianship over her children even if she is granted the right to their custody; nor can she claim any maintenance, even if she is considered the innocent party.

In Sweden, the law requires the husband to pay an allowance to his divorced wife and his children, but he is exempted from this if the wife has an income of her own or is able to support herself. It is also possible for the law to require the woman to allot an allowance to her husband should

he be unable to work or in need of money.

As for Iran, divorce is open to the man, since he can divorce his wife for any reason whatsoever; but the woman cannot seek divorce from her husband unless he is stricken with insanity or impotence, so that he is no longer able to perform his full conjugal duties.

In Holland, the law allows the wife to leave her husband's house during the time the court is considering the divorce case. But if the wife leaves her home without the court's consent, this means she forfeits her right to obtain maintenance.

In the United States of America, the scope of divorce is wide for both man and woman, and its provisions differ from one state to another. Among the grounds that permit a man to divorce his wife are his discovery that she had committed immorality before he married her, or the wife's remain-ing outside the state in which the conjugal home is located for at least ten years, or her desertion of her home for at least two years, or her addiction to intoxi-cating drink. Among the grounds that permit a woman to divorce her husband are the man's inability to provide a reasonable livelihood for her, his cruelty, and his addiction to narcotic drugs.

(3) Remarriage:

We pass now to a review of the provisions concerning remarriage in the laws of the different countries. The restrictions these provisions impose on man and woman in this field differ in many circumstances — among them the ending of the marriage by death, or its annulment by divorce, or by separation. Many

legal systems provide that legal separation does not sever the marital bonds, but puts an end to the obligations that marital relations require, including the necessity of living under one roof. The countries that follow these systems do not permit remarriage after separation.

In Norway and Sweden, a woman who has been divorced may not remarry before ten months have passed since her husband's death or her divorce from him, unless it is established that she was not pregnant at the time of the dis-solution of the marriage, or that she did not live with her husband during the said ten-month period.

In France, Italy, and Holland, the man has the right to remarry immediately after the dissolution of the marriage. The