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Tuesday 19 March 2024

Was this ground for divorce ever invoked, 1923-1970?

I have long considered the intricacies of English divorce law one of my topics of niche pedantry, and will happily, though perhaps not for my hearers, discourse of the errors made in historical fictions when invoking the dissolution of marriage as a plot-point. Also the sometimes curious lack of interest of biographers in how a wife had managed under a grossly unequal law to get quit of her husband. But I recently discovered a new twist.

I have somewhat belatedly been digging into questions a couple of people raised with me last year about Lord Dawson's contribution to the House of Lords debate on the Matrimonial Causes Bill 1936. This became the 1937 (Herbert) Act, extending the grounds for divorce beyond simple adultery in either party to include cruelty, desertion and insanity. In the course of his speech, Dawson said:

[I]t is an important omission from the Bill. In the case of homosexuality I shall ask that this be made a cause alike for men and women. It is time for equality in that matter.

 Except, I had been under the impression that homosexuality was not grounds for divorce.

However, on doing a little digging, one discovers that, going back to 1923, it appears that in theory at least, there was an anomaly that a wife could petition on the ground that her husband had, since the celebration of the marriage, been 'guilty of rape, sodomy or bestiality': but this would, presumably, mean convicted of a serious sexual crime and sent down for it. These had already been among the causes which, added to simple adultery, had provided women with grounds for divorce under the 1857 Act.

This does, though, rather preclude the kind of equality before the law that Dawson was positing, since lesbianism was not a crime under English law at the period - its depiction in literature (as in the case of The Well of Loneliness) might be deemed obscene but the actual practice was not illegal. The Amendment he suggested: 'has since the celebration of the marriage been guilty of the practice of homo-sexuality' raised considerable questions and was not accepted.

I do have remaining questions as to whether there are divorces on record in which bestiality or sodomy was the ground invoked, or whether, with the possibility of this coming into court, the husband just did not defend the action or did the stock collusive procedure of hotel room + hired co-respondent. I also wonder whether 'gross indecency' under the Criminal Law Amendment Act 1885 counted or whether a strict definition under the Offences Against the Person Act 1861 applied.

Friday 8 March 2024

IWD: A Centenary to Celebrate in 2024, and an anniversary

There have been various mentions that this year is the centenary of the first - if short-lived - Labour Government in the UK. Its coming to power (however limited that power was in practice) was greeted by the growing birth control movement of the period as a suitable opportunity to press for permitting advice to be given in local authority maternity clinics under the auspices of Public Health Departments. This had already been an aim of the movement - clinics had been set up to meet existing need but were few and far between, and were intended to provide a model for public provision.

Early in 1924 the Ministry of  Health published the report on Maternal Mortality by Dr Janet Campbell, Senior Medical Officer for Maternity and Child Welfare. It revealed shocking levels of annual death in childbirth and widespread induced abortion; and that the risks were greater the larger the family. However, among the suggested remedies, birth control was not mentioned.

On 9 May 1924 there was a substantial deputation to the new Minister of Health, John Wheatley, by a group including H. G. Wells, Dora Russell, doctors, Labour MPs, and members of the Labour and birth control movements, to ask that 'welfare centres shall be permitted to give birth control information to such mothers as may desire it'. The focus was on the lives and well-being of working-class women. There was an assumption that better-off women would be able to obtain contraceptive advice from their private medical practitioners (there is a good deal of evidence, however, see my Hidden Anxieties, that the vast majority of doctors were ill-informed on the subject even when they were willing to talk about it).

Wheatley refused to introduce so controversial a measure involving public funds without express Parliamentary direction; arguing that religious feelings were involved and that there was no public mandate. A petition with six thousand signatures demanding an end to the Ministry's opposition to birth control instruction in welfare centres was rejected, but when submitted to the National Conference of Labour Women on 14 May, they refused 'to accept a a further shelving and temporising resolution of its executive' and voted in its favour by an overwhelming 1000 to 8.

As a result, the Workers' Birth Control Group, which had already been in the planning process, was set up. Unlike the other organisations at the time, it was not establishing clinics, but activitating public opinion, and lobbying local and central government authorities for the provision of advice in publicly funded centres. For tactical reasons, it positioned itself as representing 'working mothers', and its public face was to consist of (married) 'men and women who had known the responsibility of parenthood'. An exception was made for Dorothy Jewson, MP, one of their major Parliamentary supporters; however, although Stella Browne was very much part of the group and tirelessly addressing meetings all over the country, she was not publicly associated with it. (Her open support for the legalisation of abortion was felt to be inexpedient at the particular political moment.)

In 1930, following the passage of a wide-reaching Local Government Act by the Labour Government in 1929, the Ministry of Health quietly conceded a Memorandum 153/MCW on the giving of birth control advice in local authority clinics to women whose lives were endangered by further pregnancy. At first this was issued only to Medical Officers of Health who specifically enquired about the position, but was eventually leaked in Birth Control News by Marie Stopes and disseminated by interested parties including the WBCG.

The WBCG decided that its original intention had been achieved, and dissolved itself. Several of its leading members joined Stella Browne in the struggle for abortion law reform.

However, it was to be a long time before birth control was fully accepted as part of health care. It was not integrated into the National Health Service in 1948 and the terms under which it was provided remained those formulated in the 1930s by Ministry of Health circulars 153/MCW and 1408 of 1934 (which extended the grounds upon which advice might be given). It was left in the hands of the Family Planning Association (previously the National Birth Control Association) or the discretion of individual doctors, and not included in the curriculum of medical schools. This entire process pretty much follows the general model I laid out in my 2010 article in Socialist History 36: '"No sex, please, we'e socialists": the British Labour Party closes its eyes and thinks of the electorate'.

Contraception was finally incorporated into the NHS under the NHS Reorganisation Act 1973 - free family planning services, and supplies subject to a prescription charge. In 1974 Labour returned to power and Barbara Castle, as Secretary of State for Social Services, announced the removal of the charge, irrespective of age or marital status (as had been the situation in many areas following the permissive 1967 Edwin Brook Act). So, a 50th anniversary to celebrate as well.

Images from the Workers' Birth Control Group leaflet from the relevant file in the Family Planning Association archive in the Wellcome Library, SA/FPA/A/13/95A


Monday 22 January 2024

A welcome return to Victorian values

I.e. those Victorian values embodied in Alfred Swaine Taylor's 1879 Manual of Medical Jurisprudence in his discussion of the question of abortion. In discoursing of a case in which, to his distaste. 'the medical man appeared in the capacity of an informer as well as expert', he offered the opinion that the medical man 'should refuse to... lend himself in any way as a detective for the purposes of a prosecution'.

That is, doctors were not in the business of grassing up women who had had abortions, though at that period, they would almost certainly have mainly encountered them when they were at the point of death. Swaine Taylor commented on the frequency of occurrence of miscarriage, both from natural causes and accident.

It was reassuring, in the light of the recent spate of prosecutions of women under the 1861 Offences Against the Person Act for procuring their own abortions, to read that the Royal College of Obstetricians and Gynaecologists has issued a statement that 'it is "never" in the public interest to report women who have abortions, and that they must be safeguarded'.

The organisation says it is "concerned" by the rising number of police investigations following abortions and pregnancy loss, and the effect this might have on "especially vulnerable" patients.

Dr Jonathan Lord, RCOG's medical director, told the BBC: "A law that was originally designed to protect a woman is now being used against her.

"We have witnessed life-changing harm to women and their wider families as a direct result of NHS staff reporting women suspected of crimes, and we just don't think that would happen in other areas of healthcare.

"We deal with the most vulnerable groups who may be concerned about turning to regulated healthcare at all, and we need them to trust us".

Dr Lord said he believed some NHS staff had shared information with police because they were "ignorant" about confidentiality regulations.

The centrality of concern for women's care was manifested in the early twentieth century following complaints by police and the judiciary that medics ought to make more effort to extract information about illegal abortionists from the women they treated. The Royal College of Physicians sought legal counsel and passed a resolution ‘Concerning the Duties of Medical Practitioners in Relation to Cases of Criminal Abortion’: these stated the ‘moral obligation’ to respect the patient’sconfidence. Without her consent a doctor would not be ‘justified in disclosing information obtained in the course of his professional attendance’. However, if a doctor was convinced that criminal abortion had occurred, he should urge the patient, especially should she be likely to die, to make a statement, ‘provided always that her chance of recovery are not therefore prejudiced’. If she refused to make a statement, the doctor was under no obligation to take further action except those to do with his medical attendance upon the patient.


Wednesday 27 December 2023

Archivists are voices in the wilderness?

 Like (I think) every archivist, historian, and genealogist who encountered this proposition, I was horrified by the weaselly-entitled press release from the Ministry of Justice a few weeks ago: Easier access to historic wills under new government plan: Genealogists, historians and amateur family archivists will be better able to access historic wills under proposals published today.

Who is not excited by the thought of improved digital access to a valuable historical resource?

And then we discover that nothing has been learnt from a whole long history of 'space-saving' initiatives (I can remember the days of 'microfilm the lot!!') and digital projects which are now inaccessible because the technology has moved on and it is proposed to destroy the originals except for a few 'noteworthy wills which hold historical importance'. 

Chorus of horror.

How, I also wonder, are these digitised items to be made available? Metadata? One can think of all sorts of ways these documents could be deployed for far deeper ventures in research than just the testamentary dispositions of particular individuals, but this would require some thinking about, some consultation with people who have undertaken previous projects....

They don't yet seem to have got even The National Archives on board for their deliberations, which one would have thought would have been an essential starting-point.

I see I addressed some of the questions arising here, yet again (sigh) in this post: that digital does not mean for ever, that it's not just about nostalgia for the quaintness of some past phenomenon, and that we do not know what future historians are going to think is important.

The Open Consultation is taking responses until 23 February 2024

Monday 18 September 2023

Transnational abortion in times of illegality

I was delighted to see that Mexico recently decriminalised abortion, but I also went, wait, haven't I read novels, and maybe memoirs, from a much earlier period, involving women from the USA going across the border to obtain their terminations? I know I have a couple of citations in my Literary Abortion webpage, as well as a link to an article on the Association to Repeal Abortion Laws, which helped women travel outside the USA, pre-Roe, to Mexico (also Puerto Rico and Japan), giving referrals for safe though ellegal doctors.

There's also a trope in the earlier twentieth century of women from the UK going abroad to France (Paris in particular was much mentioned) or Switzerland or the Netherlands to obtain abortions, even though the situation was no more legal in those countries. Abortion remained illegal in France until the Manifesto of the 343 called for legalisation of abortion and access to contraception in the early 1970s. There must have been networks of information about sympathetic/competent doctors. In the laters 1930s abortion was legalised in Denmark and Sweden but it would very likely have been more difficult for the foreign visitor to access given the system of bureaucratic panels.

While delving into the novelist Ethel Mannin's letters of the 1930s to her friend and former lover Douglas Goldring I found one, writing from Vienna, in which she mentions her pregnancy (undated, naughty Ethel, but probably early 1930s) and her ambivalence about continuing it, and suggesting she might go to Prague to get it terminated but that would be inconvenient for various reasons (this would not have been actually legal in Czechoslovakia at the period) and then mentioning various UK doctors who might assist her if she returned there. But Ethel was very much in progressive sex reform circles (she had her Grafenberg ring fitted by Grafenberg himself, noting that it was cheaper even with the travel there than what Norman Haire charged in Harley Street).

I'm not sure how one would go about uncovering further details of this phenomenon. Women like the Labour politician Jennie Lee, who apparently horrified Nye Bevan's sister by declaring that if by some accident she fell pregnant she 'knew what to do' had £100 and would 'go to Holland' (where abortion was not legalised until 1984), did not expand on these tantalising hints of secret women's knowledge. Letters? diaries? would this even have been written down, or, if written down, preserved beyond immediate need?

There could have been reasons of discretion for going to distant places where they were not known if they could afford it.

Friday 1 September 2023

Colin Spencer (1933-2023): bisexual novelist of the 60s

Today I saw the Guardian obituary for Colin Spencer, treating him primarily as a food writer, which he became in the later part of his career. 

However, last year I did a re-reading (because they turned up during a reorganisation of some piles of books) of his quartet of autobiographical novels, Anarchists in Love (1963), The Tyranny of Love (1967), Lovers in War (1970)  and the rather later final volume which was not in my collection but available as ebook, The Victims of Love (1978). I'm not sure whether they have 'enduring literary value' but they are certainly of historical and sociological interest

As the obituary mentions, Spencer was an out bisexual, and this was very much expressed in these novels, though these days Reg might be considered pansexual: 'I just like sex, a lot'. And it is bisexuality, not attempts to 'go straight' or conceal homosexuality for prudential reasons. 

That said, there are extremely vivid scenes of gay life at various levels, from the alleys of artsy bohemian Brighton to posh London literary circles. On the Brighton scene, re-reading Anarchists in Love after, what, maybe 40 years, I realised why the Brighton section of Queer Beyond London seemed somehow familiar!

There's also a good deal of wider relevance for the historian of sex at the period (and indeed, society in general during this time of change) - there's a certain amount on STIs, from Eddie's panic when he discovers his mistress's husband is dying of tertiary syphilis, to Matthew's experiences as a VD orderly when doing his National Service. There's also mention of contraception ('cock-socks') and abortion.

The bisexuality, however, is primarily male: while Sundy and Jane both admit to some lesbian experience (though in Jane's case possibly on an emotional rather than physical level) this appears to be 'just a phase' in primarily heterosexual lives. 

I felt that there were certain rather period gendered attitudes to Jane as a female academic - and particularly in the later volumes considerable misogyny, but given that she was based on his first wife and they had a bitter divorce during which his bisexuality was invoked over child custody, that was perhaps more individual than generic. Sundy is on the whole a sympathetic figure and indeed in his autobiography, first volume of a planned trilogy (the rest has not yet appeared), Backing Into Light: My Father's Son (2013) Spencer claims that Sundy as well as Matthew was based on himself.

The tetralogy has been reissued with introductions by Spencer in paperback and ebook by Faber Finds.

Monday 28 August 2023

Forgotten vs somewhat neglected novelists

I was recently brought up short during a re-read of Dorothy Sayers' The Unpleasantness at the Bellona Club, when Wimsey scans Ann Dorland's bookshelves: 'Dorothy Richardson—Virginia Woolf—E. B. C. Jones—May Sinclair—Katherine Mansfield—the modern female writers are well represented, aren’t they?' I think Richardson, Woolf, Sinclair and Mansfield would be familiar names to anyone with some acquaintance with women writers of the early decades of the twentieth century - but E. B. C. Jones?

In fact, Emily Beatrix Coursolles ("Topsy") Jones (1893-1966), has a remarkably substantial Wikipedia entry, which says her novels

focused on the social and psychological traumas of World War I, on large-family dynamics among young adult siblings, and on relationships among the young "liberated" middle-class intelligentsia of the Twenties. She was also known in the interwar period as a reviewer of contemporary fiction in British literary journals.

provides a useful biographical summary and plot outlines of the novels. She also has an entry in the Oxford Dictionary of National Biography

I have managed to gain a sight of a few of her novels, Quiet Interior (1920), The Singing Captives (1922), and The Wedgwood Medallion (1923), well worth reading and would like to read the others.

I shall now be adding Jones to my webpage British Women Novelists, 1910s-1960s: The 'middle-brows' along with some additional updates - I discover that there is interest being taken in Romer Wilson, and that Sarah Salt's Sense and Sensuality (1929) has lately been republished by Cutting Edge Books.

But considering these works and authors which can reasonably described as having been 'forgotten' at least for a signficant length of time, made me think of certain works and authors claimed to have been 'rediscovered' e.g. by Virago Press, but I wonder if they had ever been truly entirely lost.

There is a difference between a book which may have made a great sensation in the 1920s and then vanished, and other books which may never have gained enormous critical cred but have gone on not only being read, enjoyed and recommended, but continuing to be republished. Books which appeared in cheap reprint editions and in Penguin and later mass-market paperback formats (a substantial portion of my Winifred Holtby collection consists of the Corgi paperback editions issued, one suspects, in the wake of the success of the Yorkshire TV South Riding) - and also circulated in public libraries.

The popularity of certain works with library patrons led to the production by Cedric Chivers of Bath of New Portway Reprints, robust hardbacks specifically for libraries of works that librarians knew would be much borrowed. Paula Byrne notes in The Adventures of Miss Barbara Pym that Pym was a little cheered during her years in the wilderness of publishers' lack of interest by reprints of four of her earlier books as 'Library Association reprints by Chivers of Bath'.

I surmise that there may be studies to be done on these books which are neither critically-acknowledged  'classics' nor perennially popular genre bestsellers but go on having what was perhaps a word of mouth reputation. 

Just possibly these might be what Stella Gibbons was alluding to as ' the minor classic, a type of book that has perhaps given more pure pleasure to more readers than any other kind'? (In My American, 1939).


Thursday 1 June 2023

I suppose these days one would call this being cancelled

Have been reminded by the currently notorious case of the chemical weapons expert who was disinvited from speaking on his sphere of expertise at a government conference because of his opinions on the government expressed on social media, of a fairly trivial instance where an invitation I had received to speak at a conference was rescinded on grounds which did seem to me at the time had a flavour of 'moral panic', (I don't think the term 'woke' was much in general use at the time, but I suspect that there was a fear that I would introduce a certain, ahem, 'wokeness' into my presentation.)

(I realise this also falls rather apposite to the inception of Pride Month 2023...)

I have a minor area of expertise in the history of women in medicine in the UK, developed largely through having had to do with relevant archives over a significant period of time, leading to organising exhibitions of same, doing promotional work via lectures, etc etc. In 2013 I was approached by a rather staid heritage body preparing a major conference for 2014 - one of many celebrating the notable centenary falling in that year - to present on - actually I cannot remember after all this time whether it was just women docs or women health professionals more generally (e.g. the Almeric Paget Massage Corps) in World War I. To which I said yes, as it fell within the general remit of my duties as an archivist drawing attention to the materials in our collections.

Early in 2014 I was to give a presentation at the Florence Nightingale Museum on 'Passions Between Women in Victorian Britain' (to which I had been persuaded by the then curator). 

I think it was when this was in the process of being publicised that I received a rather nervous phone-call from the organiser of the conference indicating that concerns had been expressed and they would therefore rather I did not participate in their event. I had not in fact intended to introduce any speculations about, e.g. the relationship of Louisa Garrett Anderson and Flora Murray, as I felt I had quite enough material on, you know, the amazing and undervalued contributions women made to medical care during the Great War in the teeth of official hostility.

I hope they found someone else to speak on this important topic.

Tuesday 16 May 2023

Pretending medical conditions for journalistic clout

I have lately been seeing a lot of understandable pushback concerning the BBC Panorama documentary involving a journalist going undercover to access private diagnosis and treatment for ADHD - for which there are very substantial waiting times in the NHS. This had been described by the ADHD Foundation in their Response to BBC Panorama “Private ADHD Clinics Exposed” as

a poorly researched, sensationalist piece of television journalism. This programme has focussed on a niche issue whilst completely ignoring the broader context, including why there has been a rapid growth in private providers.  Some private providers do provide quality service. We believe the unscrupulous behaviour of some people/organisations in the private sector should be challenged, but it must also be contextualised within the wider environment of our health services.

I am not sure if anyone else was reminded of this, but it recalled to me the 1974 scandal around articles in the News of the World, subsequently published as a book, Babies for Burning, based on very dodgy undercover journalism involving abortion providers. The authors, Michael Litchfield and Susan Kentish, made unsubstantiated claims about the practices of abortion providers, including non-profit organisations such as the British Pregnancy Advisory Service, up to and including offering abortions to women who were not even pregnant. In the course of their investigations, the couple gave themselves out as seeking an abortion for Kentish, who was not pregnant: they had provided themselves with a urine sample of a confederate who was, to lend verisimilitude to their narrative.

The libel case brought by BPAS is substantially documented in their archive at Wellcome:

Much of the content of the book was found to be based on misleading evidence, as revealed in a Sunday Times article, 'Abortion Horror Tales Revealed as Fantasies'. The authors withdrew their allegations against the BPAS in a statement in open court on 18th January 1978. They ‘apologise[d] for any distress and damage’ which their allegations had caused and ‘recognise[d] that BPAS exercises the greatest care in the employment of qualified medical practitioners, and in selecting and training its counsellors.’ There is also documentation of several other separate but related cases[.]

There is also a significant group of files relating to the case in the archives of Brook, as well as Diane Munday's own file among the archives of CO-ORD: Co-ordinating Campaign for the Defence of the 1967 Abortion Act:

Papers, correspondence and press cuttings relating to statements made in the book Babies for Burning (1974) alleging that pregnancy testing agencies deliberately informed women that they were pregnant when they were not. The BPAS claimed that many of the conversations allegedly reproduced in the book were distorted by the authors. 

Litchfield and Kentish were not only found guilty of several instances of libel: they were also guilty of lying to the Select Committee on the Abortion (Amendment) Bill (1975), by submitting to it transcripts which they alleged were a faithful account of interviews and tapes recorded:

I wish, Mr. Speaker, to raise a question of privilege.... Mrs. Diana Munday, of the British Pregnancy Advisory Service, has spent 300 hours transcribing the tapes and comparing them with the transcripts produced to the Select Committee. As you may know, Mr. Speaker, apologies have been made to the British Pregnancy Advisory Service and all the allegations against it have been withdrawn.... My point is that the Select Committee was deceived by Miss Susan Kentish and by Michael Litchfield and lies were told to the Select Committee in order to mislead and influence that Committee's conclusions. This is a serious matter.

The case is discussed in Sally Sheldon, Gayle Davis, Jane ONeill and Clare Parker, 'The Abortion Act (1967): a biography', Legal Studies (2019), 39, 1835:

The investigation had a clear impact on early attempts to restrict the Abortion Act. One MP is said to have based his personal research for his 1975 abortion bill on reading the proofs, and others explicitly attributed their support for it to the book. Litchfield and Kentish were invited to give evidence to an important Parliamentary Select Committee, which in turn influenced further measures aiming to restrict the Act.

They suggest that 'While it was without doubt the most important scandal to have engulfed the Abortion Act, more than forty years on, Babies for Burning has been largely forgotten' but that 'the ongoing use of media stings... [has] become a significant and recurrent feature of [the Act's] life'.


Saturday 29 April 2023

Some minor updating as to what I've been up to

My chapter, 'The Afterlives of Victorian Scandals: The Memorable, the Neglected, the Factitious', appeared in Brenda Ayres, Sarah E. Maier (eds), The Routledge Handbook of Victorian Scandals in Literature and Culture (2023).
I have previously mentioned my chapter, 'Send in the Clones?: Naomi Mitchison and the Politics of Reproduction and Motherhood' in James Purdon (ed), Naomi Mitchison: A Writer in Time (Edinburgh UP, 2023) (glorious cover).
Also on a related topic, a tribute to the pioneer woman doctor and birth control advocate Alice Vickery, as part of Pascal Theatre Company's Women in 19th Century Bloomsbury Project. 

Wednesday 8 March 2023

International Women's Day 1923: will this centenary be celebrated?

The Matrimonial Causes Act 1923

I am not sure whether this is generally considered a major leap forward in the advancement of women in England, but the writer Clemence Dane certainly believed it was:

[T]his slip of paper is one of the most important scraps of paper in the history of women, in the history, at any rate, of English women.... [it] defined, so long as England and the English idea shall endure, the status of women: it concedes for the first time her absolute right as a human being to the same law and the same justice that man enjoys. (Clemence Dane, The Woman's Side 1926, pp. 106-7)

I.e. it legally recognised a Single Moral Standard between the sexes, rather than having a much higher bar of marital misconduct in the male for authorising the dissolution of marriage. While it did not go anything like as far in establishing the wider grounds for divorce as some bodies had advocated to the Royal Commission on Marriage and Divorce prior to the Great War, nonetheless it was a significant step in making divorce more available.

It is not entirely easy to ascertain how far women took advantage of this new measure. In spite of the difficulties under the previous law a significant number of divorces had been sought and achieved by women. Under the new law (and possibly even before), there was a social convention that, if a couple wished to divorce, and were not on completely hostile terms, they would come to an arrangment whereby, whatever the rights and wrongs of the situation, the husband would let the wife divorce him by providing evidence of adultery. This would obviously somewhat exaggerate the statistics.

Even if he was the guilty party, the man might spare the reputation of the woman he might, after all, intend to marry once his first union was dissolved, by employing the services of a hired co-respondent, who would provide 'evidence' by going with him to a hotel, where the bill would reveal that he had taken a double room. and the pair would be discovered by the maid who brought the morning tea. The actress and nightclub entrepreneur Elsa Lanchester described in her autobiography, Elsa Lanchester Herself how as a penurious young woman she would undertake this masquerade - no actual sex was involved, they would usually play cards to occupy the time. 

An instance of this 'judicial farce' was recently revealed when the papers of the solicitor who handled Wallis Simpson's 1936 divorce from her husband were opened in 2019. The hotel to which Ernest Simpson took his anonymous companion -  'the woman named' - was very proud of its reputation for discretion about its guests and therefore reluctant to disclose any information to the inquiry agent.

It was not until 1937 that AP Herbert's Matrimonial Causes Act finally extended the grounds beyond adultery, and even then the action remained adversarial and based in concepts of 'guilt' and 'innocence'.