has not only had no practical effect, but leads to
injurious results of a serious kind."[343] In England a similar state of
things has prevailed ever since divorce was established, but it seems to
have become too familiar to excite either pain or disgust. Yet, as Adner
has pointed out,[344] it has moved in a direction contrary to the general
tendency of civilization, not only by increasing the inquisitorial
authority of public courts but by emphasizing merely external causes of
divorce and abolishing the more subtle internal causes which constantly
grow in importance with the refinement of civilization.

In Austria until recent years, Canon law ruled absolutely, and matrimony
was indissoluble, as it still remains for the Catholic population. The
results as regards matrimonial happiness were in the highest degree
deplorable. Half a century ago Gross-Hoffinger investigated the marital
happiness of 100 Viennese couples of all social classes, without choice of
cases, and presented the results in detail. He found that 48 couples were
positively unhappy, only 16 were undoubtedly happy, and even among these
there was only one case in which happiness resulted from mutual
faithfulness, happiness in the other cases being only attained by setting
aside the question of fidelity.[345] This picture, it is to be hoped, no
longer remains true. There is an influential Austrian Marriage Reform
Association, publishing a journal called _Die Fessel_, or The Fetter. "One
was chained to another," we are told. "In certain circumstances this must
have been the worst and most torturing penalty of all. The most bizarre
and repulsive couplings took place. There were, it is true, many
affectionate companionships of the chain. But there were many more which
inflicted an eternity of suffering upon one of the pair." This quotation,
it must be added, has nothing to do with what the Canonists, borrowing the
technical term for a prisoner's shackles, suggestively termed the
_vinculum matrimonii_; it was written many years ago concerning the
galleys of the old French convict system. It is, however, recalled to
one's mind by the title which the Austrian Marriage Reform Association has
given to its official organ.

Russia, where the marriage laws are arranged by the Holy Synod aided by
jurists, stands almost alone among the great countries in the reasonable
simplicity of its divorce provisions. Before 1907 divorce was very
difficult to obtain in Russia, but