Why Kareem proxy marriage is the wrong approach
The case of Berthiaune V Dastous  AC 79 explains this principle better. It was explained as “If a marriage is good by the laws of the country where it is effected, it is good all the world over, no matter whether the proceedings or ceremony which constituted marriage according to the law of the place would not constitute marriage in the country of the domicile of one or other of the spouses”.
The Right Approach
“Is the type of marriage one recognised in the country in which it took place?
Was the actual marriage properly executed so as to satisfy the requirements of the law in which it took place?
Was there anything in the law of either party’s country of domicile that restricted his freedom to enter into the marriage?”