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Innocent III 'was the first who ordained the celebration of marriage in the church.' This belief is stated by Blackstone, Comment. I, 439, and was in his time traditional among English lawyers. Apparently, it can be traced to Dr. G-oldingham, a civilian who was consulted in the case of Bunting v. Lepingwell (Moore's Reports 169).* Justice Willes says that irregular and clandestine marriages were at the time of the Council of Trent looked upon as odious.' But, however, down to the time of the Council of Trent the canons on marriage were merely directory, without any nullifying clause, and the marriage although irregular and clandestine, was valid if the con-sEeeve Dom. Eel. 196. The words italicized, it seems, were first quoted by J. Woodbury in 1820 (1 N. H. 278). See also Dumaresly v. FisMy, 10 Ky. 370 for same statement.

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