At Rome divorce evolved more rapidly and more completely than in Greece. In primitive Rome we see at first, as usual, the right of repudiation allowed to the husband and forbidden to the wife. “Romulus,” says Plutarch, “gave the husband power to divorce his wife in case of her poisoning his children, or counterfeiting his keys, or committing adultery, and if on any other account he put her away she was to have one moiety of his goods, and the other was to be consecrated to Ceres.”[797] The Roman husband could also put away his wife for sterility.[798] He was, however, obliged to assemble the family beforehand for consultation. If the marriage had been contracted by confarreation it had to be dissolved by a contradictory ceremony, diffarreation.[799] In the ancient law, when the crime of the woman led to divorce, she lost all her dowry. Later, only a sixth was kept back by adultery, and an eighth for other crimes.[800] At length divorce by consent (_bonâ gratiâ_) was introduced in spite of the censors; and then both parties had liberty of divorce, only with certain pecuniary disadvantages for the husband whose fault led to the divorce. Thus the adulterous husband lost advantage of the terms which usage accorded for the restitution of the dowry. In the last stage of the law the guilty husband lost the dowry, or the _donatio propter nuptias_. Inversely, if the wife divorced without a cause, the husband retained a sixth of the dowry for each child, but only up to three-sixths.[801] The formula of the Roman repudiation recalls by its energetic conciseness the Kabyle formula, and it seems especially to relate to the property: _Res tuas habeto_.[802] The wife, even though subjected to the _manus_, obtained at last the power of divorce, by sending the _repudium_ to her husband, who was then forced to set her free from the _manus_.[803] In short, divorce became in time very easy. Cicero repudiated his wife Terentia in order to get a new dowry. Augustus forced the husband of Livia to put her away, although she was with child. Seneca speaks of women counting their years, not according to the Consuls, but to the number of their husbands. Juvenal quotes a woman who was married eight times in five years. St. Jerome mentions another who, after having had twenty-three husbands, married a man who had had twenty-three wives. Constantine, humbly obedient to the Christian spirit which had invaded his base soul, restricted the cases of divorce to three for each spouse, but always admitted mutual consent, and under Justinian the full liberty of divorce reappeared in the Code.[804]