J.A. PATIL, J.:---"Marriages are settled in heaven and they are performed on earth."

Whether and where a marriage can be dissolved is a matter in the domain of the earthly law governing the spouses. But the matrimonial laws are not common everywhere in the world and they differ from country to country. The problem arises when the parties have their domicile in one country and one of them obtains matrimonial relief in a foreign country. The moot question posed in this Notice of Motion is whether the decree passed by a Swedish Court can be recognised by this Court, as being conclusive, or not.

2. This is a case where a Hindu domiciled in India got married in civil form in New York to a Swedish woman of Christian religion, who lived with him after the marriage for about six years and bore two children to him. Thereafter, she separated from him and went back alongwith her two children to Sweden. Six years after the separation, the man went to Sweden where both of them by mutual consent obtained a decree of divorce. The man then returned back to India and got married to a Hindu woman in Vedic form of marriage from whom he has a son. The children of the first marriage now raise