legislative provisions, including (in cases where it still remains part of the law) the concept of domicile of dependency of endment, it is clear that the whole trend of American law is towards abandoning the concept of a married woman’s domicile of dependency. The obligation of support has historically rested upon the husband and has been widely relied on to justify the concept of domicile of dependency (since, if the husband is responsible for support, selection by him of the place where the family should live has been regarded as a necessary aspect of the discharge of that obligation). However, in recent years, maintenance obligations have been placed on a more equal basis between the sexes, so that the principal rationale for the concept of dependent domicile has been swept aside. Moreover, the idea that there must be a “head of the household” has given way to the notion of joint responsibility for ily. Another factor worthy of note is that the emphasis on matrimonial fault has generally been greatly reduced in divorce law in the United States. The retention of some of the exceptions mentioned supra in regard to the domicile of dependency, which were premised on the notion of matrimonial fault, would clearly be out of harmony with this development.
(3) Canada
The new domicile regarding dependency from partnered girls not can be applied into the esteem regarding split up legislation, where partnered people has actually a separate domicile. Regulations in a few provinces (including Ontario and Prince Edward Area) provides you to married females need to have another domicile in the all times.
(4) Australian continent
The general rule in Australia is that the principle of domicile of dependency prevails. For the purposes of matrimonial jurisdiction, however, married women now have an independent domicile by virtue of section 4(3) of the Relatives Rules Act 1975, which provides that “[i]n ascertaining the domicile of a party to a marriage for the purpose of this Act .
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