In
Conflict of Laws, the issue of nullity (known as
annulment in the
United States) in
Family Law inspires a wide response among the laws of different
states as to the circumstances in which a
marriage will be valid, invalid or null. As in
English Law, some classify marriages as either void or voidable; others have no concept of a voidable marriage; still others have a third category of “non-existent” marriage (e.g., Nichtehe in
Germany). The decree of nullity may therefore be no more than a declaration that no marriage had ever come into being, i.e. it is void
ab initio, or it may be equivalent to a decree of
divorce, i.e., the marriage requires a decree to dissolve it.
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