This simple means of obtaining marital freedom contains much to recommend itself to the unhappy people who are barbarously tied together to-day, in spite of their mutual antagonism of temperament and desire. In France, the Civil Code authorises divorce on the following grounds: “(1st) Adultery by the wife, or by the husband if he kept a concubine in the common dwelling-house; (2nd) Outrageous conduct or ill-usage by either of the spouses; (3rd) Condemnation to an infamous punishment; and (4th) In a certain limited class of cases by mutual consent, but only upon the conditions and under the restrictions specified, which are of the most stringent character.”[5] It is interesting to refer to the Scottish law on the same subject, particularly when it is stated by an eminent Scottish judge, Lord Mackenzie, in his work on Roman Law. “By the law of Scotland a divorce may be obtained by the husband or the wife on the ground of adultery, or of wilful desertion for four years together, without just cause, after adopting the forms of the Act 1573, c. 55, so far as these are still required.... In suing for a divorce in Scotland the wife has precisely the same rights as the husband. If she can prove adultery or wilful desertion for four years by the husband, that entitles her to take proceedings for a divorce, in the same manner as adultery or wilful desertion on her part entitles him to a similar remedy.... The action of divorce proceeds before the Court of Session, and the right to institute it is personal to the husband or the wife. As a preliminary, the pursuer is required to make oath that the suit is not collusive. In this and all consistorial actions the summons must be served upon the defender personally when he is not resident in Scotland; yet, upon evidence to the satisfaction of the court that the defender cannot be found, edictal citation will be held sufficient; but in every case where the citation is edictal the summons must be served on the children of the marriage, if any, and on one or more of the next-of-kin of the defender, exclusive of their children, when the children and next-of-kin are known and resident within the United Kingdom; and such children and next-of-kin, whether cited or so resident or not, may appear and state defences to the action.... When the husband sues for divorce on the ground of adultery, he may cite the alleged adulterer as a co-defender, and the court may order him to pay the whole or any part of the costs, or may dismiss him from the action, as may seem just.... In the case of adultery, divorce is barred by condonation or forgiveness, as well as by collusion or connivance. Recrimination cannot be pleaded as a defence to exclude the suit, but it may be stated in a counter-action, as the mutual guilt may affect the patrimonial interests of the parties.... The legal effect of divorce on the ground of wilful desertion under the Act 1573, c. 55, is, that the offending husband is bound to restore the tocher