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More than One Mrs. Mir Anwaruddin: Islamic Divorce and Christian Marriage in Early Twentieth-Century London

Published online by Cambridge University Press:  21 December 2012

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Copyright © North American Conference of British Studies 2008

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References

1 Madras was renamed Chennai in 1996. I have used the contemporary name of the city throughout this essay.

2 A series of nineteenth-century cases, Warrender v. Warrender (1835), Hyde v. Hyde (1866), In re Bethell (1887), placed polygamous marriage outside the realm of English law. For English divorce in the nineteenth century, see Stone, Lawrence, The Road to Divorce: England, 1530–1987 (Oxford, 1990), 368–89CrossRefGoogle Scholar; and Mary Lyndon Shanley, Feminism, Marriage, and the Law in Victorian England, 1850–1895 (Princeton, NJ, 1989), 22–48.

3 See Derrett, John Duncan M., Religion, Law and the State in India (New York, 1968)Google Scholar; and Galanter, Marc, Law and Society in Modern India (Bombay, 1989)Google Scholar for overviews of the development of the Indian legal system. Examples of the extensive literature on particular aspects of this topic include Washbrook, David A., “Law, State and Agrarian Society in Colonial India,” Modern Asian Studies 15, no. 3 (July 1981): 649721CrossRefGoogle Scholar; and Skuy, David, “Macaulay and the Indian Penal Code of 1862: The Myth of the Inherent Superiority and Modernity of the English Legal System Compared to India's Legal System in the Nineteenth Century,” Modern Asian Studies 32, no. 3 (July 1998): 513–57CrossRefGoogle Scholar.

4 This literature has grown large, but for some examples see, on sati, Mani, Lata, Contentious Traditions: The Debate on Sati in Colonial India (Berkeley, 1998)Google Scholar; on widow remarriage, Carroll, Lucy, “Law, Custom, and Statutory Social Reform: The Hindu Widows’ Remarriage Act of 1856,” Indian Economic and Social History Review 20, no. 4 (December 1983): 363–88CrossRefGoogle Scholar; on the age of consent, Engels, Dagmar, “The Age of Consent Act of 1891: Colonial Ideology in Bengal,” South Asia Research 3, no. 2 (November 1983): 107–29CrossRefGoogle Scholar. On the Ilbert Bill, see Sinha, Mrinalini, “‘Chathams, Pitts, and Gladstones in Petticoats’: The Politics of Gender and Race in the Ilbert Bill Controversy, 1883–1884,” in Western Women and Imperialism: Complicity and Resistance, ed. Chaudhuri, Nupur and Strobel, Margaret (Bloomington, IN, 1992), 98116Google Scholar. Sinha has also written about the age of consent issue in “The Lineage of the ‘Indian’ Modern: Rhetoric, Agency and the Sarda Act in Late Colonial India,” in Gender, Sexuality and Colonial Modernities, ed. Antoinette Burton (London, 1999): 207–21. And, of course, this literature is not restricted to India. See, e.g., Persis Charles, “The Name of the Father: Women, Paternity, and British Rule in Nineteenth-Century Jamaica,” International Labor and Working-Class History 41 (Spring 1992): 4–22. For an especially rich discussion of an attempt to achieve sexual reform in an imperial context, see Susan Pedersen's treatment of the British campaign against clitoridectomy in Kenya during the 1920s and 1930s: “National Bodies, Unspeakable Acts: The Sexual Politics of Colonial Policy-Making,” Journal of Modern History 63, no. 4 (December 1991): 647–80.

5 This brief summary points to a large, important, and sometimes contentious scholarly literature. For a particularly useful treatment of how struggles over legal pluralism produce unique systems of law, see Benton, Lauren, Law and Colonial Cultures: Legal Regimes in World History, 1400–1900 (Cambridge, 2002)Google Scholar, esp. chaps. 4 and 7. For other treatments of this process in the Indian case, see Rudolph, Lloyd I. and Rudolph, Susanne Hoeber, “Barristers and Brahmans in India: Legal Cultures and Social Changes,” Comparative Studies in Society and History 8, no. 1 (October 1965): 2449CrossRefGoogle Scholar; Cohn, Bernard S., “Law and the Colonial State in India,” in History and Power in the Study of Law: New Directions in Legal Anthropology, ed. Starr, June and Collier, Jane F. (Ithaca, NY, 1989), 131–52Google Scholar; and Anderson, Michael R., “Islamic Law and the Colonial Encounter in British India,” in Institutions and Ideologies: A SOAS South Asia Reader, ed. Arnold, David and Robb, Peter (Richmond, Surrey, 1993), 165–85Google Scholar.

6 In general, under Islamic law, the husband has the right to terminate the marriage contract, a process called talaq. Ali, Shaheen Sardar, Gender and Human Rights in Islam and International Law: Equal before Allah, Unequal before Man? (The Hague, 2000), 59 n. 63Google Scholar. Actual practice of this power varies considerably, however, not only between Sunni and Shia traditions but also in the degree to which the practice is regulated by law in different countries. See Carroll, Lucy, “Talaq Pronounced in England and Perfected by Post Not Recognized: Fatima in the House of Lords,” Modern Law Review 49, no. 6 (November 1986): 776–81Google Scholar, for a discussion of some of the complications in ascertaining the validity of a talaq in particular cases.

7 “Court of Criminal Appeal: Perjury by an Indian Barrister,” The Times, 27 July 1918, p. 4, col. B.

8 For discussions of the influence of the Hammersmith case and the erosion of its importance as a precedent after the Second World War, see P. R. H. Webb, “The Relegation of the ‘Hammersmith Marriage Case,’” Modern Law Review 25, no. 6 (November 1962): 730–34, and “Further and Better Relegation of the Hammersmith Marriage Case,” Modern Law Review 26, no. 1 (January 1963): 82–84; and Lucy Carroll, “R. v. Hammersmith Revisited: The View from India,” Modern Law Review 48, no. 4 (July 1985): 434–38.

9 Such mobility took place in a wide range of circumstances from the eighteenth to the twentieth centuries. See Spitzer, Leo, Lives in Between: Assimilation and Marginality in Austria, Brazil, West Africa, 1780–1945 (Cambridge, 1989)Google Scholar; Colley, Linda, Captives (New York, 2002)Google Scholar; and Burton, Antoinette, At the Heart of Empire: Indians and the Colonial Encounter in Late-Victorian Britain (Berkeley, 1998)Google Scholar.

10 Copy of marriage registration, Mir Anwaruddin and Ruby Pauline Sterling Hudd, 18 March 1913, The National Archives (TNA): Public Records Office (PRO), T1/11952.

11 “Examination Results,” The Times, 17 April 1912, p. 4, col. A, and “Calls to the Bar,” 28 January 1913, p. 3, col. G.

12 “Anwaruddin v. Anwaruddin: Copy Notes of Evidence,” TNA: PRO, J77/1119/3971, 2.

13 Ibid., 4.

15 Testimony of Mir Anwaruddin, ibid., 3.

16 Ibid., 5.

17 Ibid., 6, 7.

18 Ibid., 18.

20 Lahiri, Shompa, Indians in Britain: Anglo-Indian Encounters, Race and Identity, 1880–1930 (London, 2000), 68Google Scholar.

21 The Times, 24 June 1912, p. 4, col. C.

22 In 1913, there were ten appeals to the High Court, four of which were allowed, including Anwaruddin’s. “High Court of Justice: Probate, Divorce, and Admiralty Division (Divorce): Taxation, Executions, Sittings, &c., in Matrimonial Suits,” Civil Judicial Statistics (London, 1915), cd. 7807, Table XLIX, 76. To put these appeals in context, in 1913 there were 7,959 separation orders made by magistrates in England and Wales. “Courts of Summary Jurisdiction, Proceedings in Quasi-Criminal Matters,” Criminal Judicial Statistics (London, 1915), cd. 7767, Table XIV, 62.

23 The Times, 24 June 1913, p. 4, col. C.

24 Thanks to Ginger Frost for this suggestion about the role of the mode of conveying evidence.

25 “The King v. The Superintendent Registrar of Marriages for the District of Hammersmith (Ex parte Mir Anwaruddin),” 10 November 1916, TNA: PRO TS27/44.

26 See, for instance, Nehru's autobiographical account of his education for the role of a legal career and the study of law for himself and his father (An Autobiography [Oxford, 1980], 2, 4, 17–26). For a summary discussion of the education of Indian barristers in England and their place in Indian legal and political life, see Samuel Schmitthener, “A Sketch of the Development of the Legal Profession in India,” Law and Society Review 3, nos. 2–3 (November 1968–February 1969): 365–81.

27 See Deslandes, Paul R., “‘The Foreign Element’: Newcomers and the Rhetoric of Race, Nation, and Empire in ‘Oxbridge’ Undergraduate Culture, 1850–1920,” Journal of British Studies 37, no. 1 (January 1998): 5490CrossRefGoogle Scholar. On racial discrimination and antagonism suffered by Indian students, see also Rozina Visram, Asians in Britain: 400 Years of History (London, 2002), 85–86.

28 Lahiri, Indians in Britain, table 1, 5.

29 Gordon, Leonard A., Brothers against the Raj (New York, 1990), 2223Google Scholar.

30 Lahiri, Indians in Britain, 1–15.

31 “The Bar and the Empire,” Madras Law Journal 25 (1913): 33–34, reprinted from Obiter Dicta, “The Bar and Empire,” The Law Journal 47, no. 2443 (9 November 1912): 672.

32 Lawrence Committee, Testimony by Adrian Hassart Short, TNA: PRO LCO 32/3, 135.

33 Harold Laski to Oliver Wendell Holmes, 7 February 1928, in Holmes-Laski Letters, 2 vols., ed. Mark De Wolfe, abridged by Alger Hiss (New York, 1963), 2:198.

34 Patrolling racial boundaries played an important role in imperial regimes, as established by Stoler, Ann L. in “Making Empire Respectable: The Politics of Race and Sexual Morality in 20th-Century Colonial Cultures,” American Ethnologist 16, no. 4 (November 1989): 634–66CrossRefGoogle Scholar, which lays out the case for the general proposition. This insight has stimulated a rich literature about interracial sexual relationships in various imperial settings. For two very recent examples of work that deals with these issues of sexuality and racial identity in a richly detailed and nuanced way, see Buettner, Elizabeth, Empire Families: Britons and Late Imperial India (Oxford, 2004)Google Scholar; and Ghosh, Durba, Sex and the Family in Colonial India: The Making of Empire (New York, 2006)CrossRefGoogle Scholar. Stoler discussed the anxieties about the sexual danger posed to European women by indigenous men, but she takes care to note both the reality and the comparative rarity of such sexual relations, especially in comparison to the much more common incidence of concubinage between European men and indigenous women (Stoler, “Making Empire Respectable,” 642, 643). Lora Wildenthal underlines the rarity of actual incidents of marriage between white women and black African men in German Women for Empire, 1884–1945 (Durham, NC, 2001), 111–18, discussing only one such case of intermarriage, describing it as virtually unheard of. For a discussion of the perceived threat of European women becoming involved with Indian men, see Kenneth Bullhatchet, Race, Sex, and Class under the Raj: Imperial Attitudes and Policies and Their Critics, 1793–1905 (New York, 1980), 112–17, 148–52. Bullhatchet does not give many examples of this, and most of these involve very elite Indian men whose wealth and education enabled them to travel abroad. And of course, there is the case of supposed sexual insult to an Englishwoman by an Indian man at the center of E. M. Forster's A Passage to India.

35 For a sketch of this myth in the context of Malaya, see Brownfoot, Janice N., “Memsahibs in Colonial Malaya: A Study of European Wives in a British Colony and Protectorate, 1900–1940,” in The Incorporated Wife, ed. Hilary Callan and Shirley Ardener (London, 1984), 205–6Google Scholar.

36 Sarat Bose, a student at Lincoln's Inn about the same time as Anwaruddin, expressed admiration for Englishwomen and the Western concept of a freely chosen marriage partner based on love, but he returned to his wife and family in India at the end of his legal studies. Gordon, Brothers, 25.

37 Dictionary of National Biography, s.v. “Ameer Ali, Saiyid”; Memoirs and Other Writings of Syed Ameer Ali, ed. Syed R. Wasti (Lahore, 1968).

38 See Gleeson, Kate, “Sex, Wives, and Prostitutes: Debating Clarence,” in Criminal Conversations: Victorian Crimes, Social Panic, and Moral Outrage, ed. Judith Rowbotham and Kim Stevenson (Columbus, OH, 2005), 215–31Google Scholar, for a preliminary discussion of the status of marital rape in late nineteenth-century England.

39 For example, the Divorce Court held that a husband with venereal disease could not inflict the disease upon his wife with impunity. See Gail Savage, “‘The Wilful Communication of a Loathsome Disease’: Venereal Disease and Marital Conflict in Victorian England,” Victorian Studies 34, no. 1 (Autumn 1990): 35–54. In these cases, male sexual transgression and its definition as legal cruelty formed the foundation of successful divorce litigation by wives.

40 See Gopalrathnam, V. C., A Century Completed: A History of the Madras High Court, 1862–1962 (Madras, 1962), 197–98Google Scholar. Thiruvenkatachariar, after serving a lengthy term as judge in the City Civil Court, was promoted to the District Court and then the High Court in the 1920s, retiring in 1929. He was known for his conscientiousness, his “legalistic bent of mind,” and his adherence to his own views in the face of disagreement.

41 For a discussion of the application of restitution of conjugal rights in English courtrooms, especially the influential case of R. v. Jackson, see Shanley, Feminism, Marriage, and the Law in Victorian England, 1850–1895, 177–83.

42 For discussions of the Rukhmabai case, see Sudhir Chandra, “Whose Laws? Notes on a Legitimising Myth of the Colonial Indian State,” Studies in History, n.s., 8, no. 2 (1992): 187–211; Meera Kosambi, “Gender Reform and Competing State Controls over Women: The Rakhmabai Case (1884–1888),” Contributions to Indian Sociology, n.s., 29, nos. 1–2 (January–December 1995): 265–90; Antoinette Burton, “From Child Bride to ‘Hindoo Lady’: Rukhmabai and the Debate on Sexual Respectability in Imperial Britain,” American Historical Review 103, no. 4 (October 1998): 1119–46, and “Conjugality on Trial: The Rukhmabai Case and the Debate on Indian Child-Marriage in Late-Victorian Britain,” in Disorder in the Court: Trials and Sexual Conflict at the Turn of the Century, ed. George Robb and Nancy Erber (New York, 1999), 33–56; Sudhir Chandra, Enslaved Daughters: Colonialism, Law and Women's Rights (Delhi, 1998). The literature on the Rukhmabai case tends to emphasize the way in which husbands employed this legal tool in order to discipline wives, although it could be used by wives as well. In England, wives found it an invaluable mechanism for facilitating divorces based on the grounds of desertion as the courts regarded a spouse who defied a restitution order as having deserted. It would be interesting to know how often Indian litigants resorted to this process once it was available to them.

43 For an extremely interesting discussion of the anomalous legal position of Christian converts in India, see Viswanathan, Gauri, Outside the Fold: Conversion, Modernity, and Belief (Princeton, NJ, 1998), 75117Google Scholar. See also Mody, Perveez, “Love and the Law: Love-Marriage in Delhi,” Modern Asian Studies 36, no. 1 (February 2002): 223–56CrossRefGoogle Scholar, for a discussion of the political and communal complexities of facilitating interfaith marriage following upon the attempt to legislate a provision for civil marriage in India in 1872.

44 “Copy of Decree,” Madras City Court, 15 December 1913, TNA: PRO T1/11952; Sir Trevelyan, Ernest John, The Constitution and Jurisdiction of Courts of Civil Justice in British India (London, 1923), 449Google Scholar.

45 For the date of the talaq, see “Copy of Judgment, Court of Appeal, 23 November 1916, The King v. The Superintendent Registrar of Marriages for the District of Hammersmith (Ex parte Mir Anwaruddin), Copy of Transcript Notes,” TNA: PRO TS27/44; for a summary of Mir Anwaruddin's affidavits describing the talaq and its significance, see “The King v. The Superintendent Registrar of Marriages for the District of Hammersmith (Ex parte Mir Anwaruddin), Judgement, 10 November 1916.”

46 “Exhibit B, Judgement in High Court of Justice, Probate Divorce & Admiralty, 10 July 1916, by Sir Henry Bargrave Deane,” TNA: PRO TS27/44.

47 “The King v. The Superintendent Registrar of Marriages, Hammersmith. Ex parte Mir-Anwaruddin,” 1 K. B. (1917), 63–64. The description of the key events leading up to the case makes it clear that Anwaruddin was resident in England when he pronounced the talaq. The subsequent judgment that denied its validity does not rest upon that grounds but rather appears to claim that Anwaruddin's talaq would not have been valid wherever he might have been at the time he enacted it. See Webb, “Further and Better Relegation of the Hammersmith Marriage Case,” 84, for a very brief discussion of this point.

48 Mir Anwaruddin to Registrar General, 26 July 1916, TNA: PRO T1/11952; Office of Registrar General to Treasury, 29 July 1916.

49 For discussions of the increasing willingness of English courts to recognize nonjudicial divorces, see Hartley, Trevor C., “Non-judicial Divorces,” Modern Law Review 34, no. 5 (September 1971): 579–82Google Scholar; and Polonsky, Michael, “Non-judicial Divorces by English Domiciliaries (Based on Radwan v. Radwan),” International and Comparative Law Quarterly 22, no. 2 (April 1973): 343–49CrossRefGoogle Scholar.

50 Opinion of Law Officers, 15 August 1916, TNA: PRO T1/11952.

51 The presumption that a woman took on the domicile of her husband remained standard practice until the passage of the Domicile and Matrimonial Proceedings Act 1973. Cretney, Stephen, Family Law in the Twentieth Century: A History (Oxford, 2003), 112Google Scholar.

52 The precedent here, Hyde v. Hyde, actually dealt with a polygamous Mormon marriage. For an examination of the issues raised by this case, see Poulter, Sebastian, “Hyde v. Hyde—a Reappraisal,” International and Comparative Law Quarterly 25, no. 3 (July 1976): 475508CrossRefGoogle Scholar. For a discussion of recent developments in regard to the legal position of polygamy in England, see Shad, Prakash A., “Attitudes to Polygamy in English Law,” International and Comparative Law Quarterly 52, no. 2 (April 2003): 369400Google Scholar.

53 “Transcript of Hearing,” 22 August 1916, TNA: PRO TS27/44, 21–22.

54 In this respect, the imperial capital differed from some colonial settings, such as southern Rhodesia, where mixed marriages between nonwhite men and white women were indeed prohibited. Levine, Philippa, “Sexuality, Gender, and Empire,” in Gender and Empire, ed. Philippa Levine (Oxford, 2004), 140Google Scholar.

55 For the experience of Indian troops on the western front, see Greenhut, Jeffrey, “The Imperial Reserve: The Indian Corps on the Western Front, 1914–15,” Journal of Imperial and Commonwealth History 12, no. 1 (October 1983): 5473CrossRefGoogle Scholar. For overviews of the impact of participation in World War I on Anglo-Indian relations, see Wolpert, Stanley, A New History of India, 2nd ed. (New York, 1982), 286300Google Scholar; and James, Lawrence, Raj: The Making and Unmaking of British India (New York, 1997), 439–63Google Scholar. See also Visram, Asians in Britain, 169–95, esp. 185–90, for a discussion of the anxieties that led British officials to withdraw English women nurses from the care of Indian wounded beginning in November 1914.

56 “Transcript of Hearing before the Lord Chief Justice, Justice Darling and Justice Bray 21 Sept. 1916, with Solicitor General Presenting Case for Registrar,” TNA: PRO TS 27/44, direct quotations from 80–81.

57 Amending legislation that gave the same relief to a non-Christian as a Christian passed into law in 1927. The gap in jurisdiction arose because the 1869 act did not anticipate the need for a jurisdiction for mixed marriages as these were not provided for until the passage of the 1872 Indian Christian Marriage Act. Sir Smith, Henry Moncrieff-, “British India,” Journal of Comparative Legislation and International Law, 3rd ser., 11, no. 3 (1929): 160Google Scholar.

58 “Transcript of Hearing before the Lord Chief Justice, Justice Darling and Justice Bray 21 Sept. 1916, with Solicitor General Presenting Case for Registrar,” TNA: PRO TS 27/44, direct quotations from 84–85.

59 “Effect of Marriage between a Mahomedan and an Englishwoman,” The Times, 11 November 1916, p. 4, col. C.

60 “A Mahomedan's Marriage with a Christian,” The Times, 24 November 1916, p. 3, col. A.

61 Memorandum to Mr. Comyn, 14 December 1916, TNA: PRO TS27/44.

62 Testimony of “Miss L,” quoted in “Indian's Alleged Double Perjury,” The Times, 27 May 1918, p. 5, col. E; child born in February 1917, according to testimony during appeal, “Perjury by an Indian Barrister,” The Times, 27 July 1918, p. 4, col. B.

63 See Messinger, Gary S., “The Wrong Kind of Immorality: Horatio Bottomley,” in Messinger's British Propaganda and the State in the First World War (Manchester, 1992), 200212Google Scholar, for a summary of Bottomley's career that focuses on his activities during the war.

64 “To Dr. Mir Anwarrudin,” John Bull 22, no. 593 (13 October 1917): 7.

65 “A Mohammedan's Wife: Mir-Anwarrudin and His Record in the Courts,” John Bull 22, no. 598 (17 November 1917): 8.

66 “Unique Libel Case,” John Bull 23, no. 611 (16 February 1918): 1.

67 Hyman, Alan, The Rise and Fall of Horatio Bottomley: The Biography of a Swindler (London, 1972), 91Google Scholar.

68 Anwaruddin's defense counsel elaborated this argument in the Court of Criminal Appeal, reported in The Times, 27 July 1918, p. 4, col. B.

69 “Mixed Marriages” and “A Disgrace to the Bar,” John Bull 23, no. 614 (9 March 1918): 1.

70 “Mr. Mir-Anwaruddin Charged,” The Times, 6 May 1918, p. 3, col. B.

71 The Times, 27 May 1918, p. 5, col. E.

72 Ibid., 3 June 1918, p. 3, col. B.

73 Although the newspaper accounts are not clear on this point, the question of how Horatio Bottomley knew about this letter suggests that he must have been in contact with Ruby Hudd's family.

74 “Indian Barrister's Trial: The Disputed Letter,” The Times, 2 July 1918, p. 3, col. C.

75 “Mir Anwaruddin,” John Bull 24, no. 632 (13 July 1918): 1.

76 “Court of Criminal Appeal: Perjury by an Indian Barrister,” The Times, 27 July 1913, p. 4, col. B.

77 Lahiri, Indians in Britain, 122.

78 Memorandum, General Register Office, Somerset House, 24 July 1916, TNA: PRO, T 1/11952.

79 Sir Ernest J. Trevelyan, “Marriages between English Women and Natives of British India,” Journal of Comparative Legislation and International Law, n.s., 223 (1917): 223–26.

80 See Trevelyan, Raleigh, Golden Oriole: A 200-Year History of an English Family in India (New York, 1987), 439–41Google Scholar, for a brief discussion of Sir Ernest in the context of the family history. See also Who Was Who, 1916–1928 (London, 1929) for a summary of his career.

81 Trevelyan, “Marriages,” 23.

82 Sir Frederick Robertson (1854–1918) served as director of the Department of Agriculture in the Punjab, 1889–96; vice-chancellor of Punjab University, 1900–1910; and Puisine Judge of the Chief Court Punjab, 1898–1913 (Who Was Who, 1916–1928).

83 Sir Robertson, Frederick, “The Relations between the English Law and the Personal Law of Indians in England with Special Reference to the Marriage Law,” Journal of Comparative Legislation and International Law, n.s., 242 (1918): 259Google Scholar.

85 The period defined by the First World War and its immediate aftermath saw an increase in English concern about miscegenation in England, and this topic has recently attracted some important scholarly attention. See Tabili, Laura, “Women ‘of a Very Low Type’: Crossing Racial Boundaries in Imperial Britain,” in Gender and Class in Modern Europe, ed. Laura L. Frader and Sonya O. Rose (Ithaca, NY, 1996), 165–88Google Scholar; Bland, Lucy, “White Women and Men of Colour: Miscegenation Fears in Britain after the Great War,” Gender and History 17, no. 1 (April 2005): 2961CrossRefGoogle Scholar; Tabili, Laura, “Empire Is the Enemy of Love: Edith Noor's Progress and Other Stories,” Gender and History 17, no. 1 (April 2005): 528CrossRefGoogle Scholar.

86 Fanon, Frantz, Black Skin: White Masks (New York, 1967), 6382Google Scholar.

87 Nationality of Women Following Divorce, TNA: PRO DO 35/132/12. For instance, in 1933, law officers in the Dominions Office assert the absolute primacy of domicile, explicitly rejecting the decision upholding the refusal of the Hammersmith Register Office to issue a marriage license to Anwaruddin.

88 C.A.D. to Fiddes, 14 August 1914, TNA: PRO CO 111/595/24. This episode expresses the Colonial Office's concern with avoiding the public scandal of interracial sexual relationships combined with some uncertainty about whether the scandal in this case stemmed from the original marriage or the later divorce. For the increasing interest of the Colonial Office in discouraging interracial relationships, see Hyam, Ronald, “Concubinage and the Colonial Service: The Crewe Circular (1909),” Journal of Imperial and Commonwealth History 14, no. 2 (January 1986): 170–86CrossRefGoogle Scholar.

89 Antoinette Burton explores the complexities of utilizing traditional archives to unearth narratives about empire and gender in “Archive Stories: Gender in the Making of Imperial and Colonial Histories,” in Levine, Gender and Empire, 281–93. Ghosh, Durba considers the political dynamic revealed by attitudes toward archival materials that reveal miscegenation in “National Narratives and the Politics of Miscegenation: Britain and India,” in Archive Stories: Facts, Fictions, and the Writing of History, ed. Burton, Antoinette (Durham, NC, 2005), 2744Google Scholar.